EPA-600/i-^-/
October 1981
GUIDE FOR SPILL PREVENTION CONTROL AND COUNTERMEASURE INSPECTORS
by
Walter Unterberg
Robert M. Moorehead
Environmental Monitoring & Services Center
Rockwell International Corporation
Newbury Park, California 91320
Contract No. 68-03-2648
Project Officers:
John S. Farlow
Oil & Hazardous Materials Spills Branch
Municipal Environmental Research Laboratory - Cincinnati
U.S. Environmental Protection Agency
Edison, New Jersey 08817
and
!
Thomas J. Charlton
Division of Oil and Special Materials Control
0*ffice of Water Program Operations
U.S. Environmental Protection Agency
Washington, D.C. 20460
MUNICIPAL ENVIRONMENTAL RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
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DISCLAIMER
This report has been reviewed by the Municipal Environmental Research
Laboratory-Cincinnati, U.S. Environmental Protection Agency, and approved for
publication. Approval does not signify that the contents necessarily reflect
the views and policies of the U.S. Environmental Protection Agency, nor does
mention of trade names or commercial products constitute endorsement or recom-
mendation for use.
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FOREWORD
The U.S. Environmental Protection Agency was created because of increas-
ing public and government concern about the dangers of pollution to the health
and welfare of the American people. Noxious air, foul water, and spoiled land
are tragic testimonies to the deterioration of our natural environment. The
complexity of that environment and the interplay of its components requires a
concentrated and integrated attack on the problem.
Research and development is that necessary first step in problem solu-
tion; it involves defining the problem, measuring its Impact, and searching
for solutions. The Municipal Environmental Research Laboratory develops new
and improved technology and systems to prevent, treat, and manage wastewater
and solid and hazardous waste pollutant discharges from municipal and commun-
ity sources, to preserve and treat public drinking water supplies, and to min-
imize the adverse economic, social, health, and aesthetic effects of pollution.
This publication is one of the products of that research and provides a
most vital communications link between the researcher and the user community.
It describes the spill prevention, control and countermeasure (SPCC) regula-
tions , the role of the SPCC inspector, the affected facilities, and procedures
for carrying out the inspection, and also contains forms needed by the inspec-
tor for documentation and in the field. This report will be useful for both
training and reference for new SPCC inspectors.
This project is part of the continuing program of the Oil & Hazardous
Materials Spills Branch, MERL-Ci, to assess and mitigate the environmental im-
pact of oil pollution.
Francis T. Mayo, Director
Municipal Environmental Research Laboratory
Cincinnati
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ABSTRACT
This report is intended for use in training and guiding inspectors per-
forming compliance inspections and amendment inspections and documenting these
inspections to implement the Oil Pollution Prevention Regulations promulgated
in 40CFR112 for nontransportation-related onshore and offshore facilities.
The report covers the SPCC regulations, the role of the SPCC inspector,
the affected facilities, and procedures for carrying out the inspection. It
contains forms for use by the inspector in the field and for documentation.
The use of these forms will provide nationwide uniformity in SPCC report-
ing. Suggested procedures appear below in short form, applicable to all
inspections:
The SPCC Inspector's 1-2-3
1 - In field fill out "SPCC Inspection Field Sheet" (1 page) (EPA Form 7500-53)
2 - If facility in compliance If facility NOT in compliance
Fill out "SPCC Inspection Sum- Fill out "SPCC Inspection Summary Sheet"
mary Sheet" (1 page) only (EPA (1 page) (EPA Form 7500-52) and "Detailed
Form 7500-52). SPCC Documentation" (7 pages) (EPA Form
7500-54).
3 - Enter information in EPA-SPCC Data Bank:
Form A - Facility Identification
Form E - Inspection/Enforcement Report
Form S - Spill Report (if required)
This report was submitted in partial fulfillment of Task 4 of Contract No.
68-03-2648 by Rockwell International Corporation under the sponsorship of the
U.S. Environmental Protection Agency, This report covers the period April 20,
1978, to July 31, 1979, and work was completed as of February 28, 1980.
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CONTENTS
Abstract iv
Acknowledgment vi
1. Introduction 1
SPCC regulations 1
Objective 2
Contents 2
2. Role of the SFCC Inspector 4
Duties 4
Knowledge 6
Skills 7
Attire and equipment 9
Attitude and behavior 10
3. Affected Facilities and Their Spill Potential 13
Nontransportation-related facilities 13
Spill hazards 14
Spill causes . 16
4. Compliance Inspections 20
Preparation and initial contact 20
Review of SPCC plan 20
Facility inspection 23
5. Amendment Inspections Under 40CFR112.4 29
Preparation 29
Review of SPCC plan 29
Facility inspection . . . . : 30
6. Documentation of SPCC Inspection -. . . 31
References • 33
Appendices
A. Environmental Protection Agency regulations 34
B. Nontransportation-related facilities 47
C. SPCC inspection checklist 73
D. Report of SPCC inspection 87
E. EPA-SPCC data bank forms 101
Glossary 107
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ACKNOWLEDGMENTS
Discussions were held with and helpful suggestions were received from
the following EPA personnel:
Tom CharIton, Division of Oil and Special Materials Control,
Washington, O.C.
Ron Clawson, Surveillance and Analysis Division, Region IX,
San Francisco, CA
Wallace Cooper, Surveillance and Analysis Division, Region VI,
Dallas, TX
Steve Dorrler, Environmental Response Team, Edison, NJ
Jim Jaffe, Enforcement Division, Region IX, San Francisco, CA
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SECTION 1
INTRODUCTION
SPCC REGULATIONS
In December 1973, the U.S. Environmental Protection Agency (EPA) issued
in the Federal Register its Oil Pollution Prevention Regulations for
Nontransportation-Related Onshore and Offshore Facilities (40CFR112). The
purpose of these regulations is to prevent spills from nontransportation-
related facilities by establishing procedures, methods, and equipment require-
ments for owners or operators of facilities engaged in drilling, producing,
gathering, storing, processing, refining, transferring, distributing, or con-
suming oil. These regulations require the owners or operators of designated
onshore and offshore facilities to prepare a Spill Prevention Control and
Counter-measure Plan (SPCC Plan) in accordance with certain guidelines contained
within the regulations. These guidelines require the installation or construc-
tion of certain spill prevention systems depending upon the type of operation
conducted at the facility. It is the intention of these regulations that
these spill prevention systems be designed, installed, and operated according
to good engineering practices.
Associated with 40CFR112 are several other environmental regulations as
follows (complete texts in Appendix A):
40CFR109, Criteria for State, Local, and Regional Oil Removal
Contingency Plans — This regulation governs contingency plans
which are part of SPCC plans under certain circumstances when
conventional spill prevention is not feasible;
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40CFR110, -Discharge of Oil — This regulation applies to the
discharge of oil into navigable waters, adjoining shorelines,
or waters of the contiguous zone;
40CFR114, Civil Penalties for Violation of Oil Pollution Pre-
vention Regulations — Outlines enforcement procedures, with
tna-g-tTmim liability of $5000 for each day a violation continues.
The SPCC inspection program is the mechanism which the EPA uses to deter-
mine compliance with SPCC regulations. Compliance inspections enforce
40CFR112.3 by verifying that an SPCC plan exists for a facility falling under
40CFR112, that this plan is technically adequate, and that the provisions of
the SPCC plan have actually been carried out in the facility. The legal basis
for compliance inspections is contained in 40CFR112.3(b), which states, in
part:
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"Owners or operators of a facility for which an SPCC plan is
required ... shall maintain a complete copy of the plan ...
and shall make such plan available to the Regional Adminis-
trator for on-site review during normal working hours."
When a spill of a certain magnitude has occurred from a facility having
an SPCC plan, 40CFR112.4 requires submittal by the owner or operator of his
SPCC plan to the EPA Regional Administrator for review and possible amendment.
The Regional Administrator may require that the plan be amended to minimize
the possibilities of spill recurrence. After EPA review of the plan, an amend-
ment inspection may be performed which may result in additional SPCC require-
ments being specified by the EPA. The legal basis for this is contained in
40CFR112.4(d) which states, in part:
"After review of the SPCC plan ... submitted by the owner or
operator ... the Regional Administrator may require the owner
or operator ... to amend the SPCC Plan if he finds that the
Plan does not meet the requirements of this part or that the
amendment of the Plan is necessary to prevent and to contain
discharges of oil from such a facility ... and shall specify
the terms of such amendment."
EPA's SPCC regulations were to be implemented by 11 January 1975 by about
30,000 oil marketing terminals and bulk plants; about 285 oil refineries; sev-
eral thousand production facilities, both onshore and offshore, and many bulk
oil consumers. As of 1 June 1976, the EPA had completed 12,313 compliance
inspections. Evaluation of the SPCC program to date, in terms of spill his-
tories and enforcement, has disclosed variations among the EPA regions (Neal
and Dalsimer, 1978).
OBJECTIVE
Uniformity in carrying out SPCC inspections is desirable and therefore a
document which provides uniform guidance on a nationwide basis is required.
Also, personnel new to the SPCC program need to be trained in inspection and
documentation procedures.
This "Guide for Spill Prevention Control and Countermeasure Inspectors"
is to be a training and guidance report for those performing .compliance in-
spections and amendment inspections and documenting such inspections to
enforce the Oil Pollution Prevention Regulations promulgated in 40CFR112 for
nontransportation-related onshore and offshore facilities. Operators/owners
of such facilities should also find this report useful in developing their
SPCC plans.
CONTENTS
The remainder of this report is divided into Arabic-numbered sections.
Section 2 describes the role of the SPCC inspector, including the knowledge
and skills he should possess, the attitude and behavior he should exhibit when
dealing with facility personnel, and the attire and equipment he should take
into the field. Section 3 briefly covers the affected nontransportation-
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related facilities (discussed in detail in Appendix B) and their potential for
incurring oil spills. Section 4 is devoted to Compliance Inspections starting
with preparations for the inspection and then continuing with the initial con-
tact with the facility and the SPCC plan review, and ending with the facility
inspection itself. Section 5 deals with Amendment Inspections and parallels
4 in its sections. Section 6 deals with documentation of inspections for both
compliance and amendment inspections. This is followed by a section on Refer-
ences .
This is followed by a number of appendices which include the texts of the
applicable federal EPA SPCC regulations (Appendix A), a. discussion of
nontransportation-related facilities (Appendix B), an SPCC inspection check-
list (Appendix C), Report of SPCC Inspection forms (Appendix D), and EPA-SPCC
Data Bank forms (Appendix E). The report concludes with a Glossary of the most
commonly used terms.
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SECTION 2
ROLE OF THE SPCC INSPECTOR
This section deals with the SPCC inspector's role, knowledge, skills, at-
titudes, and behavior, as well as the equipment the inspector should carry and
know how to use. Both men and women may be inspectors; in what follows, the
use of a masculine pronoun will be taken as applying to women as well.
The SPCC inspector works directly or indirectly for the Surveillance and
Analysis Division or the Enforcement Division of one of the 10 U.S. EPA
Regions, shown in Figure 1. His findings and recommendations are filed in his
division, and when necessary are also transmitted to the regional Enforcement
Division for action under 40CFR114 (see Section 1 and Appendix A).
The inspector will be asked to perform both compliance and amendment in-
spections throughout the states in his EPA Region. In the case of coastal
states, this may include offshore facilities in inland waters of the United
States. Inland waters generally include those within the coastal 3-mile lim-
it, depending on the particular state. The 1977 amendments to the FWPCA ex-
tended EPA's authority for prevention activity out onto the outer continental
shelf, and additional amendments may extend the jurisdiction of Part 112 at a
later date.
DUTIES
The obvious purpose of inspecting facilities is to ensure compliance with
the FWPCA through regulation 40CFR112. But in a larger sense, it is the spirit
rather than the letter of the law which should be foremost in the inspector's
mind. While the inspector makes determinations of fact, and may ascertain that
there are discrepancies and defects in an SFCC plan or its implementation, he
must also be mindful of the most effective and equitable way in which the SPCC
plan can be brought into compliance and the overall purpose, that of minimiz-
ing oil pollution, achieved. Even though the inspector is a representative of
the EPA, a government agency, the principal attitude he should exhibit is that
of cooperation with the owner/operator of the facility in remedying a problem
in a manner which is mutually acceptable. The most successful inspections are
those which achieve the desired results through the cooperation of the owner/
operator and without the need for enforcement action.
The sequence of tasks performed by the inspector is generally the
following:
1. Obtain advance information on facility to be inspected;
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• REGIONAL HEADQUARTERS
" VII \
KANSASCIIV
AH
Figure 1. EPA Regional Offices - Standard Federal Regions
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2. Obtain and review SPCC plan, at the EPA Region (if amendment inspec-
tion) or in the field, always prior to field inspection.
3. Make field inspection, filling in inspection checklist(s) applicable
to the particular facility at the time of the inspection;
4. Write up inspection field report while still at the facility, dis-
cuss the report with the facility operator, and be sure to record
his opinions;
5. Write up inspection documentation report with conclusions and recom-
mendations; and in the case of amendment inspections, .include speci-
fic engineering changes which in your judgment should be made to
reduce future spill hazards;
6. Enter information from the inspection on EPA-SPCC Data Bank forms.
Some forms and checklists are provided in this report for use by inspec-
tors in the field. However, it is highly desirable that the documentation
report be written as much as possible in a continuous narrative style, making
each documentation report as individual to the facility of interest as pos-
sible and highlighting the specific nature, problems, etc. of that facility.
This will enable any subsequent interaction with that facility to be carried
out most effectively, as well as permit any later amendment inspection to be
as accurate as possible, comparing past and present conditions.
KNOWLEDGE
The inspector must have a good knowledge of the.basic SPCC regulation
contained in 40CFR112, especially Part 112.7 which contains the guidelines for
SPCC plans. Appendix A contains the full text of this regulation as well as
other associated oil spill regulations. . Jaffe (1978) paraphrases 40CFR112,
citing legal clarifications. A frequently used format for an SPCC plan for
production facilities is that suggested by the American Petroleum Institute in
its Bulletin D16 (API, 1976), of which the inspector should have a reference
copy.
Next, the inspector must become familiar with the SPCC plan in its vari-
ous forms. The plan contains "certification information" with information
about facility, ownership, and plan preparation, followed by sections on pre-
vention of oil spills and containment of oil, should a spill occur. The large
compendium entitled "Oil Spill Prevention, Control, and Countermeasure Plan
Review" (Pace, Inc., 1975) has a section on SPCC plans, with several examples.
The inspector should have a reference copy of and be familiar with this
document.
The inspector must also know the makeup of the various types of
nontransportation-related facilities. The facilities affected are spelled out,
in the appendix of 40CFR112 (Appendix A). Copious descriptions are contained
in the Pace report, touching on all types of facilities. Section 3 and Appen-
dix B examine these from the SPCC Inspection standpoint.
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Before Che inspector embarks on an SPCC Plan Review or a field inspection
of a facility, he must acquaint himself thoroughly with the equipment and
structures that make up that facility. Once he has a good understanding of
the way in which oil moves into the facility, within the facility, and out of
the facility, he is able to spot the places where potential oil spills can
occur. Section 3 lists specific spill hazards and causes, edited from the
Pace document.
For the case of offshore and onshore crude oil petroleum systems, an anal-
ysis of some 15,000 spill records in several states provided SPCC guidelines
for systems and components of such facilities, useful in developing and review-
ing SPCC plans (Ritchie and others, 1973). Another study investigated small
petroleum production and products distribution facilities in four regions of
the country to identify operational and economic SPCC problems. For each
type of plant, a generic SPCC plan was developed to serve as a model
(Trentacoste and others, 1980).
Having acquired a knowledge of the federal regulations, SPCC plans, the
nature of nontransportation-related facilities, and the spill-prone parts of
such facilities, the inspector is in a position to evaluate and review SPCC
plans from a regulatory and broad technical standpoint.
SKILLS
The most important part of the inspector's job is in the field. He should
have a scientific or technical background and be a good observer. Beyond ac-
quiring specific skills which are described below, he must acquire proficiency
in activities which involve making observations of drainage and facility lay-
out. In addition, the inspector should have a genuine interest in interacting
with people, even though the relationship between the inspector and the owner/
operator may be an adversary one.
The required skills fall into the following categories:
1. Reading of topographical maps and general (not specialized) inter-
pretation of aerial photographs
2. Terrain appraisal to indicate the course taken by potential flows
of spilled oil
3. Ability to determine the adequacy of containment structures and
contingency plans
4. Ability to communicate orally with owner/operator
5. Documentation skills, such as writing, sketching, and photography
These five skills will be treated in the following subsections.
Reading of Maps and Aerial Photographs
The inspector will use maps originating from different agencies during
SPCC inspections. Notably, he will use topographical maps such as those
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distributed by the U.S. Geological Survey, called "quad sheets." These maps
contain (brown) contour lines which give an indication of the topography of
the actual terrain, and (blue) lines indicative of perennial and intermittent
watercourses. Superposition of an onshore facility on a topographical map
permits the inspector to determine whether or not a discharge might reach
navigable waters. An explanation of the nature and use of topographical maps
is contained in the section on "Stationary Containment" (V.B.4) of Pace Co.
(1975).
Aerial photography has been used to clarify details on the ground where
surface accessibility is difficult and where dense vegetation exists. Spe-
cialized techniques involving color photography have been developed, notably
by the EPA Laboratory in Las Vegas, NV, applicable to SPCC inspections. Spe-
cialized differentiations in color can be used to identify variations in sur-
face conditions, including detection of oil-covered areas. Shadows can be
used to estimate the ground height of structures and thus the volume of stor-
age tanks. Aerial photographs furnished to EPA inspectors will generally
have already been interpreted and questionable areas noted by specialists.
However, the inspector generally familiar with aerial photography can use the
photos to orient the facility on a quad sheet, orient himself on the facility,
and locate important features to be examined during inspection.
Terrain Appraisal
The inspector must determine, in the field, whether there is a reason-
able spill expectation, defined as the potential flow of spilled oil from a
facility to navigable waters. He will need to estimate whether ground slopes
in and around a facility cause any spilled oil to flow out or stay contained
within the facility. He may use instruments such as a. hand level to assist
in these observations. The SPCC regulation only deals with spills reaching
surface waters. However, spills reaching surface waters by way of transport
by ground water come within the purview of 40CFR112. Since most areas in the
United States experience rainfall which runs off, and navigable waters include
intermittent streams (most storm drains ultimately lead to navigable waters),
most onshore facilities will have a reasonable spill expectation. An excep-
tion would be a desert area with negligible rainfall and no navigable waters
in the vicinity. The inspector must be able to make simple field drawings and
use topographic maps to indicate the relationship between the facility, the
course of oil spills, and navigable waters.
Adequacy of Spill Containment Measures or Contingency Plans
Frequently, the inspector will need to know the volume of above-ground
tanks of various shapes and sizes and also the storable volume within contain-
ment structures such as dikes. First he must know the dimensions of these
structures and if they are not available from plans, field estimates must be
made either by pacing or measuring, or by counting plates and seams. Gener-
ally, a containment dike must be able to store the volume of the largest tank
which it surrounds. Calculation formulas for various shapes encountered in
the field are contained in Appendix E, "Dike and Tank Volume Calculations," of
the Pace Co. report. The inspector must also be able to make a judgment as to
the strength of the structures, from field observation and elementary
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hydrostatics. Unreinforced concrete block walls, for example, when used for
diking will have strength to retain only a small hydrostatic head.
40CFR112.7(d) offers an SPCC plan alternative to stationary containment,
in the form of a strong oil spill contingency plan and a written commitment of
manpower, equipment, and materials to enforce the contingency plan. When sec-
ondary containment systems are impracticable, the owner/operator must clearly
demonstrate such impracticability. The contingency plan then becomes part
of the SPCC plan and the inspector must be able to make a judgment as to its
adequacy, guided by 40CFR109 (Appendix A).
Oral Communication Skills
The inspector will be involved in face-to-face conversations and tele-
phone conversations with a variety of facility personnel, ranging from upper
management to on-site supervision and workers. In all these contacts he must
be able to express himself clearly and concisely, sticking to the business at
hand. He should make a record of important conversations, noting the time,
the place (or if it was a telephone conversation), the other person, and the
main points of what was said on both sides, with quotes of important
statements.
Documentation Skills
In the course of the field inspection, the inspector may have occasion to
take photographs in the facility and to make field sketches and maps. He
should always ask permission before using his camera. He will be filling out
the SPCC Inspection Checklist (Appendix C) and the Report of SPCC Inspection
(Appendix D). The most important and permanent of these documents is the last-
named because it furnishes the actual evidence for any subsequent enforcement
action, whether it results in a court case or not. The Report of SPCC Inspec-
tion includes documentation which should be written up in sufficient detail so
that even if the persons associated with the inspection, whether representing
the owner/operator or the government, are no longer available, the report can
stand on its own. It should be written in narrative form and it may be neces-
sary to include sketches, maps, and/or photographs.
ATTIRE AND EQUIPMENT
The inspector will be meeting with facility personnel in city offices,
field offices, in onshore facilities, and on offshore platforms. In each
place, his attire should be suited to the occasion and match that of his
counterparts. When going into the field, he should carry a hard hat and
pocket knife, and wear tear-resistant clothes and oil- and slip-resistant work
shoes/boots with safety toes, gloves, and raincoat as necessary. All safety
attire and equipment should be nonsparking, not produce static electricity,
and comply with OSHA regulations. In his car he should carry an intrinsically
safe camera with film. Also, a cassette tape recorder might be useful. These
two devices would normally not be used unless special circumstances arose or
the regional policy required it, and in all cases only with the consent of the
facility owner/operator. The inspector should carry a rugged briefcase, the
suggested contents of which are listed below:
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• Identification/credentials, with photo
• SPCC Inspection checklist (Appendix C) blanks
• Documentation Report of SPCC Inspection (Appendix E) blanks
• SPCC Inspection Field Report (Appendix D) blanks
• Tablet (8V x 11" min.)/sketch pad
• 12-inch scale and 50-foot tape measure
• Shorthand notebook (for log/notes)
• Tank and dike volume formulas or nomographs
• Standard symbols listing and template(s)
• Copies of 40CFR112 (Appendix A) (one dozen min.)
• Maps of areas, including highway and topographical
• Aerial photos (if available)
• SPCC plan for facility, if available
• Extra ballpoint pen, pencils (various colors)
• Three-ring notebook or clipboard (this will hold inspection forms
and copies of 40CFR112)
• Pocket electronic calculator (in working condition)
• Hand level and range finder
ATTITUDE AND BEHAVIOR
The overall role of the SPCC Inspector has been discussed above, in
terms of "matter" and "manner." -The "matter,",consisting of knowledge,
skills, and equipment that the inspector is expected to possess, has been
covered. The "manner" will be covered here.
It is a fact of life that as the world shrinks, individuals and organi-
zations become more interdependent and are less and less able to live indepen-
dently of others. The inspector needs to realize (as the owners/operators
should realize) that we are all interdependent and that regulatory agencies
such as the EPA are not enemies of business. They are, in fact, partners.
However, if something goes awry in this partnership a severe adversary rela-
tionship can develop, which can be detrimental to all concerned. The inspec-
tor cannot totally avoid such a relationship, but he can minimize it by proper
attitude and behavior.
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In any telephone contacts, which may precede face-to-face meetings, the
inspector should establish his image as a firm but polite EPA representative.
When visiting a facility, he should be mindful not only of the general ameni-
ties that a guest observes, but should be particularly aware of specific
taboos with regard to smoking, alcohol, drugs, and firearms. Under no cir-
cumstances should he visit a facility when under the influence of alcohol or
drugs. He must not take alcoholic beverages, illegal drugs, and firearms
into a facility. If a smoker, he should ask permission to smoke if visiting
an office area or other designated smoking area. The greater part of facili-
ties that handle oil will be designated non-smoking areas, and there may be
state laws governing the carrying of matches and cigarette lighters in such
areas.
Access to facility areas is at the discretion of the owner/operator. If
access to any area is denied to an inspector, he should not challenge this,
but make a note of the incident. . In cases of significant noncooperation, a
court order to permit access can be obtained.
During the Inspection, there will be frequent routine legal questions
regarding time/extensions, applicability, penalties, and so forth, which are
quite clear in 40CFR112 and can be answered in a straightforward manner. How-
ever, occasionally a difficult legal question may arise. At this time, it
would be advisable for the inspector to clarify his role, e.g., "I'm here to
evaluate engineering plans — I'm not qualified to give legal opinions; there-
fore, you will need to discuss those areas with the EPA attorney." Include
the name of an appropriate attorney in the Regional Enforcement Office or the
Regional Counsel as a contact.
Some specific "do's" and "don'ts" are listed below:
Do Be;
. Businesslike
Friendly
. Knowledgeable
. Helpful/Informative
Cooperative
Considerate
Firm (not stubborn)
Don't Be;
. Hostile/belligerent/arrogant
. Personal (with criticism)
. Insulting
. Wasteful of the owner/operator's time
. Disinterested in the owner/operator's problems
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The willing target of insults/abuse from facility personnel —
leave at once
. Argumentative
. Subjective
Impatient
No one can be expected to have all these desirable personality, charac-
ter, and attitudinal traits all the time, but it is essential for the inspec-
tor to strive to have a basic understanding of the "road blocks" to doing an
effective job that he can unintentionally set up.
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SECTION 3
AFFECTED FACILITIES AND THEIR SPILL POTENTIAL
NONTRANSPORTATION-RELATED FACILITIES
The SPCC regulations affect "Nontransportation-Related Onshore and Off-
shore Facilities." These are defined in the Appendix to 40CFR112 (reprinted
in full in Appendix A of this report) as falling into 11 categories, briefly
described as follows:
(a) Fixed onshore and offshore oilwell drilling facilities
(b) Mobile onshore and offshore oilwell drilling platforms, barges,
derricks, etc.
(c) Fixed onshore and offshore oil production structures, platforms,
derricks, and rigs
(d) Mobile onshore and offshore oil production facilities
(e) Oil refining facilities
(f) Oil storage facilities
(g) Industrial, commercial, agricultural, or public facilities which
use and store oil (including large oil-immersed transformers)
(h) Waste treatment facilities
(i) Loading racks, transfer hoses, etc., used to transfer oil to and
from highway vehicles or railroad cars
(j) Highway vehicles and railroad cars used for transport of oil
within a nontransportation-related facility
(k) Pipeline systems used for the transport of oil within a
nontransportation-related facility
The term "oil" means oil of any kind (animal, mineral, and vegetable)
and in any form'(including crude, refined products, sludge, refuse, oil mixed
with wastes other than dredged spoil). Excluded are facilities associated
with the handling or transferring of oil in bulk to or from a vessel.
Further, only those facilities are affected which could reasonably be
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expected to discharge oil in harmful quantities into waters defined as navi-
gable and which have non-buried aggregate storage capacity greater than 1320
gallons or non-buried storage capacity greater than 660 gallons in a single
container or which have underground buried storage capacity in excess of
42,000 gallons.
In Appendix B there is a detailed discussion of typical nontransportation-
related facilities from the SPCC standpoint, emphasizing features prone to
spills. Appendix B is divided into (1) Onshore Nonproduction-Related Facili-
ties, (2) Onshore Production and Drilling/Workover Facilities, and (3) Off-
shore Production and Drilling/Workover Facilities.
SPILL HAZABDS
The information in the next few pages ("Spill Hazards" and "Spill
•Causes") is adapted from the Pace Company report, 1975. Discounting catas-
trophic accidents such as major fires, earthquakes, or explosions, most oil
spills resulting in environmental degradation can be classified as (1) equip-
ment omissions or failures, and (2) operators' errors. Adequate design,
proper equipment selection, careful inspection, and prompt correction of de-
ficiencies can prevent almost all damage from the first classification. Auto-
mated monitoring and safeguards can prevent many operational errors. However,
no hardware can take the place of adequate operator training and supervision.
Many spills are of small volume, one or two gallons, but if these spills
occur frequently, the effect on the environment can be significant. Large
spills which might occur if a large storage tank were to rupture can be equal-
ly detrimental, although the occurrence might be less frequent. Table 1 has
been prepared based on an evaluation of both the probability and severity of
potential spills. The relative importance of each is a matter of experience
and judgment.
Data do not exist on the probability and severity of spills for the fa-
cilities described in this report. The information presented is based on
actual experience with spills for the facilities. An attempt has been made
to present the relative importance of spills by type. Naturally, there will
never be a full consensus on any type of numerical ranking of probability/
severity. However, this evaluation, although somewhat arbitrary, should be
of value as a guide in determining the relative importance of each piece of
equipment and each operation having a potential for oil spills.
Table 1 lists an overall view of the probability/severity of spills.
However, a more accurate determination of spill potential can be obtained by
assessing the following factors for a particular facility under review:
Nature and amount of oil handled
. Frequency of use of piping, loading rack, tank drain, etc.
Operation conditions: temperature, pressure, flowrates
. Condition of equipment
14
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TABLE 1. AREAS OF POTENTIAL SPILL HAZARDS*
Tank
BJUI7MEOT
Tanks
Gauges
Sampling facilities
Shell and bottom*
Underground seepage
Heating coils
Containment dikes
Oik* drains
Pio«. Valves S Fitting
Seal failure
Valve seen packing
Gaskets
Pipe rapture
Pumos 4 Mechanl^fll Eauip1
Seels
Lubricating systems
Loading Stations
Fill safeguards
Curbs and drains
tfaste Disposal
Oil sumps
Separators
Site drainage
Pits
OPERATIONS
Tanks
Filling/overfilling
Sampling
Cleaning
Dike draining
Pipes. Valves & Fittings
Maintenance
Collision
Pumps
Maintenance
Loading Racks
Overfills
Loading drips
Waste Disposal
Monitoring
Maintenance
H/3 M/3
a/3 H/3
L/l L/l
L/l L/l
M/2
M/2 M/2
H/2
M/3 M/3
M/2 H/3
L/l L/l
oent
M/2 M/3
L/l
H/2
M/2 M/3
M/2 M/3
H/l L/2
a/i H/i
H/2 M/3
H/l L/2
H/2
H/2
H/l
H/3 H/3
H/2
H/3
H/2 M/3
M/l L/2
Probability
R - High, occurs frequently
M - Medium, could occur periodically
L - Low, could occur on less frequent
M/3
L/l
L/l
M/2
M/3
M/3
L/l
M/3
L/l
H/2
M/2
M/2
M/3
L/2
M/2
L/2
R/3
M/2
H/3
M/3
L/3
KZY:
occasions
Power
Plants
M/3
L/l
L/l
M/l
M/2
L/2
M/3
M/3
L/l
M/2.
M/2
M/2
L/2
M/l
M/3
L/2
L/2
M/2
H/3
M/3
L/3
Industrial Onshore
Plants Drilling Production
H/3
H/3
L/l
L/l
L/2
M/2
M/2
H/2
H/2
L/2
H/2
H/2
M/2
M/2
H/2
H/l '
H/2
M/l
M/2
H/2
L/l
H/2
M/2
L/2
M/3
L/l
M/3 L/2
M/2
L/l L/l
M/2
M/2
L/l
a/3 H/I
a/ 3
H/2
M/2
H/2
M/l
H/2 M/2
M/2 M/2
M/2 H/l
H/3
H/2
H/2
H/l H/3
L/l
H/2 H/3
H/2
H/3
M/2 H/2
H/2 L/2
Severity
Offshore
Produc ciou
M/2
L/l
L/l
M/2
M/2
L/l
H/2
H/2
H/2
H/2
L/2
L/3
L/2
H/2
H/2
H/2
L/l
1 - Major cleanup required
2 - Intermediate cleanup required
3 - Minor cleanup required
* Adapted from Pace Company Consultants and Engineers, 1975. In training manual for Oil Prevention Control and
Countermeasure Plan Seview.
15
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Degree of operator responsibility
Distance to water
SPILL CAUSES
The following is a list of specific causes of potential spills for each
facility type. These lists are intended to augment the subheadings of Table
1, explaining how spills have occurred at each of the facilities listed. At
any specific facility, adequate safeguards or adequate maintenance may mini-
mize or negate the potential for spills. However, each item is worthy of
inspection to properly evaluate the spill expectation (Pace Co., 1975).
Bulk Storage Facilities — Tank Farms and Tankage, Including Drums
Spills due to overfilling of tanks
Rupture of tanks
Leaks in pipe, valves, pumps, fittings, and other equipment
Leaks in containment dikes
Inadequate secondary containment systems
Oil flow from diked area through open dike valve
Level instrument failure allowing tank overfilling
Piping and tank damage by collision with mobile equipment
Spills from water drawoff from tanks
Spills from tank bottom cleanout and sludge disposal
Improper disposal of samples
Overflow of oil/water separation equipment by rainfall flooding
Poor maintenance of pipe, valves, pumps, fittings, and other
equipment
Plugging of drainage system by debris
Oil/water separation equipment with insufficient treatment capacity
Spills from heating .coils in heavy fuel tanks
Spills from line flushing
Spills from pipe and tankage changes
Spills from underground storage tanks
. Possible sabotage
Bulk Handling Facilities — Terminals. Pipelines
Spills from quick-connect coupling operation and damaged loading
connections
Overfilling tank trucks, tank cars, barges, tankers, etc.
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Bulk Handling Facilities — Terminals, Pipelines (continued)
. Lack of curbs, drains, and spill collection system
Improper operation of oil/water separator
. Leaks from loading arms, especially joints and gaskets
Improper disposal of sludge from product filters
Insufficient sump capacity (should be equal to volume of largest
compartment of tank truck or rail car)
. Operators incorrectly setting loading meters and tanks overfilling
Level switch or sump pump failure on oil sumps
Spills from ruptured hoses
Spills from truck or rail cars caused by moving before completely
disconnecting hoses or loading arms
Possible sabotage
User Facilities — Airports
Leaks from quick-disconnect couplers
. Filter sludge disposal
. Tank sample disposal
Cleanup of spills in sumps
. Leaks from pump seals and other equipment due to poor pump
maintenance
Spills from storage facilities over or above ground
User Facilities — Power Plants
Spills from heating coils in heavy fuel tanks
. Leaks and spills associated with railroad tank car and truck
unloading facilities
Leaks from pipe, valves, pumps, fittings, and other equipment
Leaks from tank mixer stuffing boxes
Spills and overfilling of tanks
Sludge disposal from tanks
. Line flushing oil disposal
. Spills from storage facilities
User Facilities — Industrial Plants
Spills due to manual transfer of oil
Spills from storage tanks
17
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User Facilities — Industrial Plants (continued)
Tank damage as a result of collisions with vehicles
Spills caused by lack of secondary containment systems
Spills from oil burners
Overfilling of tanks
Leaks from pipe, valves, pumps, fittings, and other equipment
Leaching from oily wastes
Spills from deliveries of fuel oil and oil products
Spills from machinery and cutting fluid operations
Spills from storage facilities
Drilling and Workover
Dike leaks and overfilling of the reserve pits
Spills at the mud preparation site
Spills from drum and small tank storage of engine and machinery
lube oils
. Spills and leaks from fuel tanks
Machinery leaks from rotary table, draw works, and generators
Spills from drill pipe racks
Spills and overflow from settling pit, shale shaker, and mud
suction pit
. Leaching from cuttings and shale
Sand cleanout spills
. BOP failure; blowout
Flooding of waste pits due to heavy rainfall
Onshore Production
Leaks from capped and abandoned wells
Spills from pipe, valves, pump fittings and other equipment
. Gathering line leaks
Gathering line rupture by equipment collision
. Gathering line breakage by rainfall runoff
Tank leaks and ruptures
. Tank overfilling
. Rod pump stuffing box leaks
Gauging spills, sample disposal
18
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Onshore Production (continued)
Transfer hose, coupling, and loading rack spills
Blowout
Salt water pit overflow
Christmas tree leaks
. Tank cleanout
Water drawoff sump overflow spills
Offshore Production
. Deck leaks and spills
Sand erosion of pipe, valves, and fittings
Fuel and lube oil spills
Pump seal and packing leaks
Pipe, valve, and fitting leaks
. Drips from draw works, rotary tables, and engines
. Blowout of well
Subsurface valve failure
Sand cleanout and handling spills
19
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SECTION 4
COMPLIANCE INSPECTIONS
PREPARATION AND INITIAL CONTACT
Once a facility or series of facilities In a certain area has been
selected for compliance Inspection, the inspector should try to obtain as much
advance data as possible. These data will include location, names and titles
of operating personnel, name of owner, type of activity, storage capacity,
data on other facility equipment, normal working hours, climate, precipitation,
etc. In this connection it is very useful to take aerial photographs for they
can reveal not only the sizes of tanks and other facility items, but also oil-
stained areas which show residual oil, presumably from previous spills. The
general case, though, is that the facility will not have been previously iden-
tified and no data will be available. Most compliance inspections will be
surprise inspections without warning to the owner or operator.
Alternately, an initial contact may be made with the owner or operator,
usually by phone, for an early review of SPCC Plan(s). Such a review meeting
may be attended by a number of people from the owner/operator's organization,
especially if it is a large organization. Here the inspector will present his
credentials and explain precisely the reasons for his visit and his desire to
be cooperative in giving any additional explanations desired and in scheduling
facility inspection visits at times convenient to the owner/operator.
It will be very helpful if the inspector can obtain a copy of the SPCC
plan or plans which pertain to the facility or facilities he intends to inspect.
In general, it is preferable to review the SPCC plan before actually visiting
the facility so that time can be saved during the actual field inspection be-
cause the working of the facility and its spill potential can first be explored
on paper.
REVIEW OF SPCC PLAN
In order to determine the adequacy of an SPCC plan, it is recommended that
the facility not be surveyed prior to review of the SPCC plan, although many
facilities may have been surveyed by EPA's aerial reconnaissance efforts. If
the plan is properly prepared, the inspector will be able to formulate a very
clear picture of the facility. However, if the facility'is surveyed first,
the inspector may assume (from memory) that a particular area is discussed in
the SPCC plan. Occasionally, for one reason or another, the facility will have
been visited prior to reviewing the SPCC plan, and then it is important that
the plan be reviewed extra carefully and the facility thoroughly inspected
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again. — the inspector should always visit the facility after reviewing the
SPCC plan. Both actions may, of course, be carried out in succession during
a single visit to the facility.
Two forms for field use in SPCC plan review and facility inspection have
been devised. The "SPCC Inspection Checklist" (Appendix C) for all types of
facilities is provided for the inspector to make sure he has covered all the
requirements in his review. This Checklist completely parallels the SPCC
Guidelines set forth in 40CFR112.7. The items, in order, are: proper contain-
ment provisions or an alternate spill contingency plan; onshore nonproduction-
related facilities; onshore oil production facilities; onshore drilling and
workover facilities; offshore oil drilling, workover and production facilities;
and facility operation items such as inspection, records, security, personnel
and training. In the case of simple facilities and experienced inspectors,
the Checklist (Appendix C) may be omitted.
The "SPCC Inspection Field Sheet (Appendix D) is a one-page writeup in
the field of the findings of the inspector, based on his SPCC plan review and
subsequent facility inspection. "SPCC Inspection Summary Sheet" and the "De-
tailed SFCC Documentation" in Appendix D are for detailed documentation of the
SPCC inspection (see Section 6). The Field Sheet is EPA Form 7500-53.
SPCC Plans — Small Facilities
Many of the inspections will involve relatively small facilities, such as:
Bulk oil storage/distribution
Service stations
. A small oil producer (three or four wells)
. Miscellaneous (boat marinas, industrial and agricultural users, etc.)
These facilities are simple enough so that an inspector can review the
SFCC plan without preliminaries. In general, the inspector needs to follow
the order on the "SPCC Inspection Field Sheet" form (Appendix D) after he has
quickly skimmed through the plan for a general overview. There are 12 items
on the form, to be filled out in the field. As a guide, instructions appear
on the reverse of the Field Sheet, EPA Form 7500-53 (App. D). More specific
instructions appear in the following paragraphs:
Item 1 of the form is self-explanatory and includes the trade name of the
facility. It is important that the "location" be as precise as possible, e.g.,
"on Hwy 35, 7.7 miles south of Sherman, Texas"; or, "on the south shore of Lake
Texoma, approximately one mile west of the Hwy 77 bridge"; or, "5208 N. Elm,
Des Moines, Iowa"; or, "Latitude 29° 44' 25" Longitude 90" 7' 35" (Lake
Salvadore Oil Field, Jefferson Parish, Louisiana)".
Item 2 should include information about both the owner (of the facility,
of the products stored, of the equipment), and the operator (is he a lessee,
consignee, or an employee? Is he the one "responsible" for the facility —
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including oil spill prevention?). The preceding information is important for
establishing an effective spill prevention program and for EPA Enforcement
Division attorneys who may have to initiate legal proceedings.
3 lists the oil materials that are being stored aboveground and bur-
ied, by type and size of container. Sufficient data shall be recorded such
that a subsequent change in the facility will be evident at a follow-up inspec-
tion. Tanks that alternatively contain different liquids should be so noted in
the SPCC plan. Plans that specify buried bulk storage should be carefully
checked and verified since such storage is rare. Facilities that store large
quantities of bulk lube oil will usually need an SPCC plan since it will usu-
ally be stored aboveground.
Item 4 should include information about the adequacy of the plan in gen-
eral, and specific information about any deficiencies in the plan. The "Com-
ments" of Item 10 and attachments can be utilized to provide as much detail as
required to provide a complete critique of the plan. The inspector should,
after completing his review of the plan, review his findings with the operator
so that he thoroughly understands the situation. The inspector should also
strive to negotiate any differences and report: the results of the negotia-
tion, what actions the operator will take, and when he will take the actions.
Obviously, the major critical area of concern in spill prevention is secondary
or backup containment for the storage tanks and the loading/unloading rack.
The inspector should review the SPCC plan with special emphasis on these areas.
Item 5, "Date of Inspection," refers to the actual visit to the facility.
Item 6 needs to include the name, registration number, and state of reg-
istration of the certifying Professional Engineer. This certification infor-
mation is usually found at the front of the SPCC plan, but sometimes on the
last page. If the facility has changed, an amendment to the plan may have
been prepared and should be so noted by the inspector. Such an amendment also
requires certification.
Item 7 — the date of certification needs to include the date on which
the SPCC plan was certified and the dates of any amendments to the plan. Ac-
tually, the date is not required by 40CFR112 and may not exist.
Item 9 should specify the distance and direction to the nearest named
stream, river, lake, bayou which will receive runoff from the facility. If
that body of water is relatively insignificant, then the distance and direc-
tion to the next significant body of water should also be identified. If the
facility runoff goes to a storm drain, the ultimate receiving water should be
named.
Items 5. 8, 9, 10, 11, and 12 are to be filled in after actual field in-
spection of the facility.
SPCC Plans — Large /Complex Facilities
These SPCC plans would cover facilities such as oil/ gas production sys-
tems where numerous wells, tank batteries, pipelines, and pieces of processing
22
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equipment are involved. It also might include large storage terminals which
are located along ship channels, harbors, etc., and have barge pipelines and
railroad loading facilities.
Due to the complex nature of these facilities, it is preferable to begin
the SPCC plan review with a thorough understanding of the total system. For
example, an offshore oil/gas field might include the following geographically
different facilities, each with its own SPCC plan:
. Nine Tank Batteries
Two Compressor Platforms
. One Boat Fueling Dock
One Living Charters Facility
One Maintenance Facility
. One Central Oil Storage Facility
Operationally, these facilities all work together as a total system, even
though the total area encompassed may be quite large. Occasionally (because
of the complexity of the system) a spill hazard situation may be overlooked and
it is up to the inspector to aid the operator in uncovering the problem area.
This can be best accomplished by an overall review of system drawings, maps,
etc. which can be related to the various SPCC plans.
Once an understanding of the entire system is gained, the inspector and
the operator can begin to make decisions regarding: (a) which facilities will
be reviewed, (b) where are the maximum spill hazards, (c). inspection schedules,
(d) transportation and manning arrangements for all facility inspections.
Using the "SPCC Inspection Checklist" (Appendix C) as a technical guide-
line, the inspector should begin reviewing the SPCC plan(s). For a normal
compliance inspection, the review of the SFCC plan can proceed in the same
fashion as that described previously for a "small facility" and as shown on
the "SPCC Inspection Field Sheet" (Appendix D). For facilities which are a
part of a large oil production field, the facility and the field need to be
identified in addition to the trade name, type of facility, and location —
for example:
1. Name of Facility, type of facility, and location. XYZ Oil Co.;
Tank Battery #3, Dog Lake Field; Terrebonne Parish. Louisiana —
Lat. 29° 10' 50'; Long. 90° 52' 10".
FACILITY INSPECTION
Frequently the inspector will not have had a chance to find out whether
a facility has an SPCC plan and he will be making a surprise, or "cold" facil-
ity inspection in the field. In such a case he should contact the facility
owner/operator, identify himself as an EPA inspector, and ask for the SPCC
23
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plan for that facility. If no plan exists, he should first determine the oil
storage capacity at that facility and by comparison with the SPCC regulation
application criterion of 40CFR112.1, determine if the storage capacity is suf-
ficient to fall under the SPCC regulations. The applicability criteria call
for a total non-buried storage of more than 1320 gallons of oil or a single
container capacity of over 660 gallons, these for aboveground storage; or a
capacity of 42,000 gallons or more of buried storage. In all cases, there must
be a reasonable expectation that an oil spill would reach waters defined as
navigable in harmful quantities.
If the oil capacity of the facility is sufficient to fall under SPCC the
inspector should determine whether there exists a reasonable spill expecta-
tion from the layout of the facility, topographical maps, known precipitation,
measured or estimated slopes, etc. If there is no reasonable spill expecta-
tion, a very rare situation in most parts of the country, the inspector should
terminate the visit. However, if a reasonable spill expectation does exist,
the inspector should proceed, as outlined below. When there is a valid SPCC
plan he should proceed as described immediately following.
Facility Inspection With Valid SPCC Plan
After the SPCC plan has been reviewed, it is essential that the facility
be thoroughly inspected to determine if the SPCC plan has been properly imple-
mented, or if the plan needs to be amended to reflect changes in the facility
since the plan was originally prepared. Facility owner/operators must amend
SPCC plans, according to 40CFR112.5, when there is a change in facility design,
construction, operation, or maintenance which affects the oil spill potential.
Also, they must conduct a review every three years to see if an amendment is
necessary. Since the potential fines which can be levied for failure to imple-
ment SPCC plans are quite high, it is critical that the inspector exercise the
utmost care and objectivity during this phase of the inspection process.
To determine if the SPCC plan has been implemented, the inspector will
need to have with him: a copy of the SPCC plan*, the Report of SPCC Inspec-
tion forms (Appendix D), the SPCC Inspection Checklist (Appendix C), and any
other review notes he has made.
A good starting point in the facility inspection is to examine the testing
and inspection records for the facility (last item in Checklist). This is a
very important area of implementation and may provide the inspector with valu-
able information about the general condition of the equipment, specific equip-
ment items which are causing most of the problems, oil spill occurrences, etc.
The lack of adequate records usually implies one of the following: the plan
did not specify record-keeping and/or testing/inspection requirements, the
operator is not aware of the requirements, or the operator does not care. The
inspector should report the situation accordingly, and try to resolve any prob-
lems with the operator.
* Note: The SPCC plan should always be returned to the operator at the con-
clusion of the inspection. If a copy is needed by the inspector for his
records, he shall obtain the owner's permission and pay for the reproduc-
tion costs.
24
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Examination of the facility itself can begin either where the oil enters
the facility (at the headers, unloading area), or where the oil either leaves
the facility or is stored (at the pipeline pumping unit, storage tanks, truck
loading rack, etc.). The starting point of the inspection is mainly a matter
of personal choice, but it seems to work better if the inspection progresses
in a direction which is contrary to the flow, e.g., for a production facility,
start at the storage tanks, then to the heater-treaters, then to the separa-
tors, etc. Regardless of the direction chosen, it is important to conduct the
inspection in an orderly serial fashion, i.e., avoid a random inspection
process.
Assuming he decides to begin (in reverse) with the storage tank area/
platform, he should inspect all aspects of the area, to verify that:
The tanks are structurally sound
. Liquid level sensors are used (if specified)
The secondary containment is as specified
The drain system is satisfactory
Drains are locked closed (onshore only)
Piping and supports are in good condition
The number and size of the tanks is as specified
There is no oil in the containment area
For an offshore oil storage platform, the floor and curbs of the platform
need to be checked to verify that no liquids can seep through, and the drain
system piping must be examined to verify that it is tight and will not leak .
liquids. Frequently, the equipment covers large areas and it may be necessary
to crawl around under the platform and determine if there is evidence of the
platform or drain pipes leaking. (In Gulf area, watch for snakes — especi-
ally under platforms!) All offshore platforms, which are subject to spilled
oil, need to have adequate drainage and containment systems to catch spilled
oil.
The inspection of the facility continues to the next equipment area, which
might be treaters or separators (in the case of oil production), or to loading/
unloading areas (in the case of a bulk oil plant). Much of the same concern
about some form of containment will be focused upon this area as it was for
the tank storage area. Wherever oil is being handled, oil spills will occur
at one time or another, and must be controlled.
As deficiencies are uncovered during the facility inspection, they should
be made known to whomever is accompanying the inspector. At the conclusion of
the facility inspection, the inspector will summarize his findings and include
them in Item 8 of the SPCC Inspection Field Report. The inspector's findings
should be openly and completely reviewed with the owner or operator of the
25
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facility at the conclusion of the visit.
If agreement cannot be reached on the findings, the inspector should ask
the owner/operator if he would like to have his opinions included in the re-
port. If so, the inspector should ask him to go slow so that his comments
can be written down word for word. It is very important that the inspector
not paraphrase, substitute, or leave out any words. It is preferable that the
owner/operator observe the words as they are being written down and initial
his comments. Alternately, he may want to send along a note as an attachment
to the report.
It is well for the inspector to realize that he is not a ppliceman, judge,
attorney, etc. He is merely a reporter who is trained in the technical aspects
of spill prevention, control, and countermeasures. Since his reporter's notes
are private and confidential, they are never to be left with anyone other than
the designated representative of the EPA Regional Administrator or another
authorized Government employee.
Facility Inspection Without Valid SPCC Plan
Occasionally, a facility will have an "SPCC Plan" that is one or two
pages in length, and does not address all or any of the requirements of
40CFR112. Such a document is not to be considered a valid SPCC plan, even if
it has been properly certified. The inspector shall make a note of such an
invalid plan and advise the owner/operator accordingly. Also, a facility that
is required to have an SPCC plan by law may be found to have no SPCC plan at
all.
In such cases, it is important that the inspector proceed with the inter-
view and the inspection of the facility to complete the SPCC Inspection Field
Sheet — except Items 6, 7, and 8, which have to do with the review of the
SPCC plan. Item 4 ("Is an SPCC plan available?") is important because the in-
spector must document his evaluation of the owner's need to have an SPCC plan;
and, specify why, if the owner believes he does not need to have an SPCC plan
for his facility (e.g., — "we only used that tank during the oil embargo,"
or, "we have only been in operation about a year — I thought I had two years
to prepare a plan," or, "I thought that the law only applied to facilities that
were close to a large navigable river like the Red River or the Mississippi
River," etc.). Due to the potentially serious nature of noncompliance, it is
imperative that the inspector be objective, accurate, and comprehensive about
his evaluation.
Item 9 ("Name of water body that potential spill could enter") is obvi-
ously a factor in the evaluation of the "need to have a plan," but due to the
fact that oil, in most areas, does flow to a stream eventually during a heavy
prolonged rain and when the ground is saturated, very few facilities will be
exempt due to their location from water. However, to avoid possible future
legal problems, it is recommended that a careful analysis of the direction of
flow to the nearest named body of water (lake, stream, etc.) be performed.
Item 10 ("Comments") can include quotes from the owner/operator and shall
be used to record all pertinent information. As a minimum, it will specify
26
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what, if any, spill prevention, control, and countermeasure equipment is being
utilized, and indicate when preparation and implementation of an SPCC plan may
be expected.
After all the data have been obtained, the inspector should briefly review
40CFR112 and leave a copy with the owner/operator. It is advisable to explain
(in a friendly, non-threatening manner) to the operator the legal ramifications,
penalties, etc. of not being in compliance. He must be given to understand
that the law is reasonable and important and that it is in his own best inter-
est to get into compliance as soon as possible. If he asks for help in prepar-
ing the SPCC plan or for a recommendation of a professional engineer, the in-
spector must decline on all points to avoid any conflict of interest and unpro-
fessional conduct. He may refer him to the state authority which performs
registration of Professional Engineers, or a. professional organization which
may have a list of engineers with SPCC experience.
Facility Inspection With Impracticable Oil Containment
Every SPCC plan must address itself to the prevention of oil spills and
the containment of oil, should a spill occur. Normally, oil containment is
achieved by the provision of dikes, berms, sumps, catchment basins, baffles,
and the like. Under 40CFR112.7(d) it is recognized that it is impracticable
for certain facilities, both onshore and offshore, to institute stationary
containment devices. Instead, a "strong oil spill contingency plan following
the provisions of 40CFR109" and a "written commitment of manpower, equipment,
and materials" for control and removal of spilled oil must be provided. When
these items appear in an SFCC plan, the inspector must first determine whether,
in his judgment, it is indeed impracticable to build stationary containment
devices, and whether the owner or operator has demonstrated such impractica-
bility. Many offshore facilities and some onshore locations which do not per-
mit all-around containment of tanks are obvious examples. Once the inspector
has satisfied himself that a strong contingency plan and commitment of man-
power and materials are called for, he must examine these very closely.
In this connection, he must use the detailed criteria set forth in
40CFR109 (Appendix A) under these general headings:
• Definition of the authorities, responsibilities, and duties of all
... to be involved ... in planning or directing oil removal operations;
• Establishment of notification procedures for the purpose of early
detection and timely notification of an oil discharge;
• Provisions to assure that full resource capability is known and can
be committed during an oil discharge situation;
• Provisions for well-defined and specific actions to be taken after
discovery and notification of an oil discharge; and
• Specific and well-defined procedures to facilitate recovery of dam-
ages and enforcement measures as provided for by state and local
statutes and ordinances.
27
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Before the inspector approves this feature of an SPCC plan, he must
examine all the steps in such a scenario, including the availability of applic-
able equipment, materials, and supplies, both locally and regionally, adequate
to remove the maxlTnum oil discharge to be anticipated. He must agree that
there is a "strong" oil spill contingency plan and associated written commit-
ment, sufficiently effective to contain the mairtmm spillage which could occur.
If he is not satisfied that this is the case, he should note any deficiencies
in the containment features of the SPCC plan and require that these be
strengthened.
28
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SECTION 5
AMENDMENT INSPECTIONS UNDER 40CFR112.4
PREPARATION
When there has been a "triggering" spill as defined in 40CFR112.4(a), the
owner must file with the Regional Administrator information including an SPCC
plan with amendments, if any, incorporating the cause of the spill(s), counter-
measures, equipment repairs or replacements, and additional preventive measures
taken or contemplated to minimize the possibility of recurrence. The same in-
formation must also be sent by the owner/operator to the State water pollution
agency which may conduct a review and make recommendations to the Regional
Administrator. The Regional Administrator may require that the owner/operator
amend the SFCC plan for the facility and specify the terms of the amendment.
An amendment inspection will normally be required to determine if such an amend-
ment is necessary and, if so, what operations should be addressed in the amend-
ment. Before conducting an amendment inspection, the inspector must make him-
self thoroughly familiar with materials submitted by the owner/operator and
the State, including a description of the facility. He is then ready to make
a review of the SPCC plan.
REVIEW OF SPCC PLAN
The inspector shall review the original SPCC plan, the information regard-
ing the spills, and the corrective actions taken, if any, to determine if ap-'
propriate measures are being taken to eliminate the cause(s) of the spills.
He is not restricted to evaluating just the equipment which failed, but he may
examine all aspects of the SPCC plan to determine if other areas need changing.
The technical procedure for reviewing the SPCC plan is the same as in a
compliance SPCC plan review, which is described in the preceding section.
However, since a spill has occurred, the inspector will have additional infor-
mation, furnished by the owner/operator as required by 40CFR112.4(a), includ-
ing drawings, maps, and operational data. The SPCC plan review and the facil-
ity inspection may result in a requirement by the Regional Administrator that
the SPCC plan be amended, specifying the terms of the amendment. The owner/
operator may ask for a reconsideration of the decision by the Regional Admin-
istrator. He may also appeal the final decision of the Regional Administrator
to the EPA Administrator. The owner/operator has 30 days after receiving the
final notice from the Regional Administrator or the EPA Administrator in which
to incorporate the amendment into his SPCC plan and he has an additional six
months in which to implement the amendment.
29
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After the amendment has been implemented, the inspector may visit the
facility and again review the SPCC plan and, based upon the data previously
submitted and an examination of the facility, determine whether or not the
amendment has been implemented.
Due to the added complexity of an amendment inspection, it is recom-
mended that his comments regarding the SPCC plan be recorded directly on the
Detailed SPCC Documentation forms (Appendix D), which may also be used for
recording the facility inspection, described in the following paragraphs.
FACILITY INSPECTION
At the outset, it is to be remembered that the inspector carries a
greater responsibility in an amendment inspection than in a normal compliance
inspection. He also has much more authority to change the spill prevention
aspects of a facility.
The amendment inspection itself is identical to the facility compliance
inspection and the procedure will not be repeated here. Extra care should be
given to the cause of the original spill, and to the assessment of any cor-
rective action taken by the owner/operator. However, he should carefully
examine all other areas of the facility.
The conclusion of the amendment inspection is identical to that of the
compliance inspection. It will include a review of the results of the in-
spection with the owner/operator, and a summary of the changes which need to
be made in either the SPCC plan or the facility. After the review, the in-
spector should thank the owner for his hospitality, give him names/addres-
ses/ telephone numbers of people to call or write if he has any additional
questions, and take his leave.
30
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SECTION 6
DOCUMENTATION OF SPCC INSPECTION
The final phase of the SPCC Inspection process is the documentation, to
be written on blank forms that are to be completed for both Compliance In-
spections and Amendment Inspections. They are in Appendix D, "Report of
SPCC Inspection," as EPA Forms 7500-52 and 7500-54. There are eight pages.
The first, Part B, is the "SPCC Inspection Summary Sheet" and if the facility
is in compliance, nothing more is required. If the facility is not in com-
pliance, Part C, "Detailed SFCC Documentation" in seven items (seven pages)
is to be filled out. Item 1 is a facility description, Item 2 describes the
receiving water in case of a spill, Item 3 is for comments by the inspector
and by the owner/operator, Item 4 is devoted to the SPCC plan review for all
inspections, Item 5 is for SPCC Amendment Recommendations in the case of an .
Amendment Inspection, Item 6 is one or more field drawings, and Item 7 is one
or more photographs.
As a guide to filling out Part B (EPA Form 7500-52) and Part C (EPA Form
7500-54), instructions have been placed on the face of Part B and on the last
page (page 8, following Item. 7) of Part C. These forms are available at the
EPA Regions.
The inspector should prepare the documentation as soon as possible after
the actual inspection, using the Inspection Checklist (Appendix C) and SPCC
Inspection Field Sheet (Appendix D), plus other notes as raw materials.
Timely preparation of the documentation will permit impressions still fresh
from the inspection to be part of the report. In fact, portions of Parts B
and C may be filled out in the field. The emphasis is entirely on narrative
writing; all the items in the facility observation report are intended to be
narrative in nature where quantitative data are not involved. The documenta-
tion must be clear and complete enough to stand by itself. It may be required
in the future when memories are dim or the principals may no longer be avail-
able to bear witness.
This documentation format is useful for both compliance and amendment
inspections. Item 4 of the "Detailed SPCC Documentation" is to be devoted to
the SPCC plan review for a statement of inadequacies in the SPCC plan or its
implementation. Item 5 should contain SPCC plan amendment recommendations to
the Regional Administrator in the nature of engineering changes in the spill
prevention control, and countermeasure equipment or changes in facility oper-
ation that should be added to the SPCC plan and implemented in the facility.
31
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The "Report of SPCC. Inspection," including the documentation, is kept in
the files of the Regional Office, and may be used for enforcement purposes.
An added documentation feature should be the use of the EPA Oil and Spe-
cial Materials Control Division's National Computerized SPCC Data Bank.
Three blank forms are used to enter the information on the computer. These
forms appear in Appendix E, and are as follows:
Form A - Facility identification - contains information similar to
that in the SPCC Inspection Field Sheet
Form E - Inspection/Enforcement Report - contains information from
the SPCC Inspection Summary Sheet
Form S - Spill Report - if required
The documentation on the National SPCC Data Bank is very important be-
cause it permits later retrieval of inspection information when triggering
spills and facility changes have taken place. It also keeps account of the
causes of spills that can be used to reinforce or amend the SPCC regulation.
32
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REFERENCES
American Petroleum Institute. 1976. Suggested Procedure for Development of
Spill Prevention Control and Countermeasure Plans. API Bulletin D 16. Dallas,
Texas. 8 pp. plus forms.
Jaffe, James. 1979. Oil Pollution Prevention. The Blue Book. Spill Control
Association of America, Southfield, Michigan. 15 pp.
Neal, E. and A. Dalsimer. 1978. Evaluation of the Oil Spill Enforcement Pro-
gram (no report number). Chi Associates, Inc., Arlington, Virginia. 69 pp.
plus appendices.
Pace Company Consultants and Engineers, Inc. 1975. Oil Spill Prevention, Con-
trol and Countermeasure Plan Review. Department of Environmental Science and
Engineering, Rice University, Houston, Texas. 389 pp. plus appendices.
Ritchie, J.E., Jr., F.J. Allen, Jr., R.M. Feltes, R.Q. Foote, Q.A. Shortt,
E.B. Bell, and J. Winn. 1973. Petroleum Systems Reliability Analysis: A
Program for Prevention of Oil Spills Using an Engineering Approach to a Study
of Offshore and Onshore Crude Oil Petroleum Systems, 2 vols. EPA-R2-73-280a
and b. Office of Research and Monitoring, U.S. Environmental Protection
Agency, Washington, D.C.
Trentacoste, N.P., G.R. Bierman, and James Cunningham. 1980. SPCC Practices
at Small Petroleum Facilities. EPA-600/7-80-004. Industrial Environmental
Research Laboratory, U.S. Environmental Protection Agency, Cincinnati, Ohio.
33
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APPENDIX A
ENVIRONMENTAL PROTECTION AGENCY REGULATIONS
The following pages contain reproductions from the Code of Federal Regula-
tions (CFR), CFR Title 40 - Protection of the Environment, Parts 109, 110, 112,
and 114.
Part 109 is titled "Criteria for State, Local, and Regional Oil Removal
Contingency Plans. Part 110 is "Discharge of Oil," Part 112 is "Oil Pollution
Prevention: Nontransportation-Related Onshore and Offshore Facilities, and
Part 114 is "Civil Penalties for Violation of Oil Pollution Prevention Regula-
tions: Nontransportation-Related Onshore and Offshore Facilities.
40CFR112 was last amended March 26, 1976 (see p. 39). A proposed modifi-
cation was published May 20, 1980, in the Federal Register, Vol. 45, No. 99,
pp. 33814-33826. The comment period expired July 21, 1980, but the new regu-
lation has not yet been promulgated. When a new 40CFR112 takes effect, the
holder of this report is requested to substitute the new regulation for the one
printed here.
34
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131:0701
ENVIRONMENTAL PROTECTION AGENCY REGULATIONS
ON CRITERIA FOR STATE, LOCAL AND REGIONAL OIL REMOVAL CONTINGENCY PLANS
(40 CFR 109; 36 FR 22485, November 25, 1971)
PART 109 - CRITERIA FOR STATE,
LOCAL AND REGIONAL OIL
REMOVAL CONTINGENCY PLANS
Sec.
109.1 Applicability.
1092 Definitions.
109 J Purpose and scope.
109.4 Relationship to Federal response actions.
109.5 Development and implementation criteria for State,
local and regional oil removal contingency plans.
109.6 Coordination.
AUTHORITY: The provisions of this Part 109 issued
under sec. 110X1XB), '84 Stat. 96, 33 U.S.C.
1161(JX1XB).
§109.1 Applicability.
The criteria in this part are provided to assist State, local
and regional agencies in the development of oil removal
contingency plans for the inland navigable waters of the
United States and all areas other than the high seas, coastal
and contiguous zone waters, coastal and Great Lakes ports
and harbors and such other areas as may be agreed upon
between the Environmental Protection Agency and the
Department of Transportation in accordance with section
ll(jXl)(B) of the Federal Act. Executive Order No. 11548
dated July 20, 1970 (35 F.R. 11677) and section 306.2 of
the National Oil and Hazardous Materials Pollution Con-
tingency Plan (35 F.R. 8511).
§109.2 Definitions.
As used in these guidelines, the following terms shall
have the meaning indicated below:
(a) "Oil" means oil of any kind or in any form,
including, but not limited to. petroleum.'fuel oil, sludge, oil
refuse, and oil mixed with wastes other than dredged spoil.
(b) "Discharge" includes, but is not limited to. any
spilling, leaking, pumping, pouring, emitting, emptying, or
dumping.
(c) "Remove" or "removal" refers to the removal of the
oil from the water and shorelines or the taking of such
other actions as may be necessary to minimize or mitigate
damage to the public health or welfare, including, but not
limited to, fish, shellfish, wildlife, and public and private
property, shorelines, and beaches.
(d) "Major disaster" means -any hurricane, tornado,
storm, flood, high water, wind-driven water, tidal wave,
earthquake, drought, fire, or other catastrophe in any part
of the United States which, in the determination of the
President, is or threatens to become of sufficient severity
and magnitude to warrant disaster assistance by the Federal
Government to supplement the efforts and available re-
sources of States and local governments and relief organiza-
tions in alleviating the damage, loss, hardship, or suffering
caused thereby.
(e) "United States" means the States, the District of
Columbia, the Commonwealth of Puerto Rico, the Canal
Zone, Guam. American Samoa, the Virgin Islands, and the
Trust Territory of the Pacific Islands.
(0 "Federal Act" means the Federal Water Pollution
Control Act, as amended, 33 U.S.C. 1151, et seq.
§109.3 Purpose and scope.
The guidelines in this part establish minimum criteria for
the development and implementation of State, local, and
regional contingency plans by State and local governments
in consultation with private interests to insure timely,
efficient, coordinated and effective action to minimize
damage resulting from oil discharges. Such plans will be
directed toward the protection of the public health or
welfare of the United States, including, but not limited to,
fish, shellfish, wildlife, and public and private property,
shorelines, and beaches. The development and implementa-
tion of such plans shall be consistent with the National Oil
and Hazardous Materials Pollution Contingency Plan. State,
local and regional oil removal contingency plans shall
provide for the coordination of the total response to an oil
discharge so that contingency organizations established
thereunder can function independently, in conjunction
with each other, or in conjunction with the National and
Regional Response Teams established by the National Oil
and Hazardous Materials Pollution Contingency Plan.
§109.4 Relationship to Federal response actions.
The National Oil and Hazardous Materials Pollution
Contingency Plan provides that the Federal on-scene
commander shall investigate all reported spills. If such
investigation shows that appropriate action is being taken
by either the discharger or non-federal entities, the Federal
on-scene commander shall monitor and provide advice or
assistance, as required. If appropriate containment or
cleanup action is not being taken by the discharger or
non-Federal entities, the Federal on-scene commander will
take control of the response activity in accordance with
section 1 l(cXl)of the Federal Act.
§109.5 Development and implementation criteria for
State, -local and regional oil removal contingency plans.
Criteria for the development and implementation of
State, local and regional oil removal contingency plans are:
Copyright C 1972 by Th« Bureau of National Affairs, Inc.
35
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131:0702
FEDERAL REGULATIONS
(a) Definition of the authorities, responsibilities and
duties of all persons, organizations or agencies which are to
be involved or could be involved in planning or directing oil
removal operations, with particular care to clearly define
the authorities, responsibilities and duties of State and local
governmental agencies to avoid unnecessary duplication of
contingency planning activities and to minimize the poten-
tial for conflict and confusion that could be generated in an
emergency situation as a result of such duplications.
(b) Establishment of notification procedures for the
purpose of early detection and timely notification of an oil
discharge including:
(1) The identification of critical water use areas to
facilitate the reporting of and response to oil discharges.
(2) A current list of names, telephone numbers and
addresses of the responsible persons and alternates on call
to receive notification of an oil discharge as well as the
names, telephone numbers and addresses of the organiza-
tions and agencies to be notified when an oil discharge is
discovered.
(3) Provisions for access to a reliable communications
system for timely notification of an oil discharge and
incorporation in the communications system of the capa-
bility for interconnection with the communications systems
established under related oil removal contingency plans,
particularly State and National plans.
(4) An established, prearranged procedure for requesting
assistance during a major disaster or when the situation
exceeds the response capability of the State, local or
regional authority.
(c) Provisions to assure that full resource capability is
known and can be committed during an oil discharge
situation including:
(I) The identification and inventory of applicable equip-
ment, materials and supplies which are available locally and
regionally.
(2) An estimate of the equipment, materials and supplies
which would be required to remove the maximum oil
discharge to be anticipated.
(3) Development of agreements and arrangements in
advance of an oil discharge for the acquisition of equip-
ment, materials and supplies to be used in responding to
such a discharge.
(d) Provisions for well defined and specific actions to be
taken after discovery and notification of an oil discharge
including:
(1) Specification of an oil discharge response operating
team consisting of trained, prepared and available operating
personnel.
(2) Predesignation of a properly qualified oil discharge
response coordinator who is charged with the responsibility
and delegated commensurate authority for directing and
coordinating response operations and who knows how to
request assistance from Federal authorities operating under
existing national and regional contingency plans.
(3) A preplanned location for an oil discharge response
operations center and a reliable communications system for
directing the coordinated overall response operations.
(4) Provisions for varying degrees of response effort
depending on the severity of the oil discharge.
(5) Specification of the order of priority in which the
various water uses are to be prptected where more than one
water use may be adversely affected as a result of an oil
discharge and where response operations may not be
adequate to protect all uses.
(e) Specific and well defined procedures to facilitate
recovery of damages and enforcement measures as provided
for by State and local statutes and ordinances.
§109.6 Coordination.
For the purposes of coordination, the contingency plans
of State and local governments should be developed and
implemented in consultation with private interests. A copy
of any oil removal contingency plan developed by State and
local governments should be forwarded to the Council on
Environmental Quality upon* request to facilitate the
coordination of these contingency plans with the National
Oil and Hazardous Materials Pollution Contingency Plan.
Environment R«port«r
36
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S-330
131:0901
ENVIRONMENTAL PROTECTION AGENCY REGULATIONS
ON DISCHARGE OF OIL
(40 CFR 110; 41 FR 49810, November 11, 1976)
Trtlaao Protection of the Environment
CHAPTER I — ENVIRONMENTAL
PROTECTION AGENCY
PART 110— DISCHARGE OF OIL
See.
110.1 Definitions.
UOJ AppUcaDlUty.
110.3 Discharge Into navigable waters harm-
ful.
110.4 Discharge Into conttguoua zone harm-
ful.
110 J Diaeharge prohibited.
1104 Exception for veeael anginas,
110.7 Dispersants.
1103 Demonstration project*.
110.9 Hotioe.
Atrnsoarrr: Sees. 311(b> (3) and (4) and
SOI (a) ot the Federal Water Pollution Con-
trol Act Amendments of 1973 (33 U.S£. 1391
ttaeq.).
§ 110.1 Definition*.
As used in this part, the following
terms shall have the meaning Indicated
below:
(a) "Oil" means oil ox any kind or In
any form. fr»*1"'*t'"g. but not limited to.
petroleum, fuel oiL sludge, oil refuse, and
oil mixed with wastes other than dredged
spoil:
(b) "Discharge" includes, but is not
limited to, "iy spilling, ****r'T>gj pump-
ing. pouring., emitting, emptying or
dumping;
(c) "Vessel'' means every description
of watereraft or other artificial contriv-
ance used, or capable of being used, as a
means of transportatioa on water other
than a public vessel:
(d) "Public vessel" means a vessel
owned or bareboat chartered and oper-
ated by the United States, or by a State
or political subdivision thereof, or by a
foreign nation, except when such vessel
is engaged in commerce;
(e) "United States" means the States.
the District of Columbia, the f-f^rnm^
wealth of Puerto Rico, the Canal Zone.
Ouam. A™****" Samoa, the Virgin Is-
lands. and the Trust Territory of the Pa-
cific T**"****!
(f) "Person" includes an individual.
firm, corporation, association, end a
(g) "Contiguous zone- "•«"« the en-
tire zone established or to be established
by the United States under article 24 of
the Convention on the Territorial Sea
and the Contiguous Zone;
(h) "Onshore facility" means any fa-
cility (including, but not Hmttod to motor
vehicles «™«< rolling stock) of any
located in. on. or under, any *""J within
the United States other *fr«" submerged
land: >
U> "Offshore faculty** means any
facility of any kind located in. on, or
under, any of the navigable waters of the
United States other **»«» a vessel or pub-
lic vessel:
(J) "Applicable water quality stand-
ards" means State -water quality stand-
ards adopted by the State and approved
by EPA pursuant to section 303 of the
Federal Act or promulgated by EPA pur-
suant to that section:
ck) "Federal Act" means the Federal
Water Pollution Control Act, as
amended. 33 U.S.C. 1251. etseq;
(D "Sheen" means an iridescent ap-
pearance on the surface of water;
(m> "Sludge" means an aggregate of
oil or oil and other mntftr of any kind
in any form other than dredged spoil
having a combined specific gravity equiv-
alent to or greater than -water:
§ 110.2 Applicability.
The regulations of this part apply to
the discharge of oil into or upon the wa-
ters of the United States, adjoining
shorelines or into or upon the waters of
the contiguous zone, prohibited by sec-
tion 311 (b) (3) of the Federal Act.
§ 110.3 Discharge into navigable water*
harmful.
For purposes of section 311(b) of the
Federal Act. discharges of such quanti-
ties of oil into or upon the navigable wa-
ters of the United States or adjoining
shorelines determined to be harmful to
the public health or welfare of the United
States, at all times and locations and
mvi*r all circumstances and conditions.
except as provided in i 110.6 of this part.
include discharges which:
(a) Violate applicable water quality
standards, or
(b) Cause a «i«« or sheen upon or dis-
coloration of the surface of the water or
adjoining shorelines or cause a sludge or
emulsion to be deposited beneath the
surface of the water or upon adjoining
§ 110.4 Discharge into contiguous zone
harmful*
For purposes of section 311 (b) of the
Federal Act. discharges of such quantities
of oil into or upon the waters of the con-
tiguous OTHP determined to be harmful
to 'the public health or welfare of the
United States, at all times and locations
and under all circumstances and con-
ditions, except as provided in . 110.6. in-
clude discharges which:
(a) Violate applicable water quality
standards in navigable waters of th»
United States, or
(b) Cause a film or sheen upon or dis-
coloration of the surface of the water or
adjoining shorelines or cause a sludge
or emulsion to be deposited beneath the
surface of the water or upon adjoining
shorelines.
§ 110.5 Discharge prohibited.
As provided in section 311 of the
Federal Act. no person shall discharge or
cause or permit to be discharged into
or upon the navigable waters of the
United States, adjoining shorelines, or
into or upon the waters of the contiguous
zone any oil. in harmful quantities as
determined In 55110.3 and 110.4 except
'as the same may be permitted in the
contiguous zone under Article IV of the
International Convention for the Pre-
vention of Pollution of the Sea by Oil.
1954. as amended.
§110.6 Exception for vessel engines.
For purposes of section 311 (b) of the
Federal Act. discharges of oil from a
properly functioning vessel engine are
not deemed to be harmful; but such oil
accumulated in a vessel's bilges «»n*n not
be so exempt.
§ 110.7 DUpenanta.
Addition of dispersants or emulsiners
to oil to be discharged which would cir-
cumvent the provisions of this part is
prohibited.
§ 110.8 Demonstration project*.
Notwithstanding any other provisions
of this part, the Administrator of the
Environmental Protection Agency may
permit the discharge of oil into or upon
the navigable waters of the United States.
adjoining shorelines, or into or upon the
waters of the contiguous zone, in connec-
tion with research, demonstration proj-
ects, or studies relating to the prevention.
control, or abatement of oil pollution.
§ 110.9 Notice.
Any person in charge of any vessel or
onshore or offshore facility shall, as soon
as he has knowledge of any discharge of
oil from such vessel or facility in viola-
tion of J 110.5. immediately notify the
appropriate agency of such discharge in
12-24-76
Copyright
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131:0902 FEDERAL LAWS
accordance with sucn procedures aa the scribe. The procedures for such notice an 33 C7R Part 153. Subpart B, 41FR12S28
Secretary of Transportation may pre- sec forth In U.S. Coast Guard regulations, ec seq. (March 25.1976).
Environment Reporter [S*c. 11 (LSI
38
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S-314
131:0931
ENVIRONMENTAL PROTECTION AGENCY REGULATIONS
ON OIL POLLUTION PREVENTION
(40 CFR 112: 38 FR 34164, December 11, 1973; Amended by 39 FR 31602,
August 29, 1974; 41 FR 12657, March 26, 1976)
PART 112—OIL POLLUTION PREVENTION
Non-transportation Related Onshore and
Offshore Facilities
AirmomrrT: Sees. 311 (J) (1) (C). 311U) (2).
S01(a). Federal Water Pollution Control Act
(See. 2. Pub. U 93-MO. 86 Stas. 816 et sec..
(33 T7J3.C. 1291 et «eq.)): See. 4. Pub. L.
93-900. 88 Stat. 887: 5 U.S.C. Bear?. Flan of
1970 No. 3 (1870). 33 FS 1B623. 3 CPR 1966-
1970 Comp^ E.O. 11739. 38 PS 21243. 3 CFB.
§ 112.1 General applicability.
(a) This part establishes procedures.
methods and equipment and, other re-
quirements for equipment to prevent the
discharge of oil from non-transporta-
tion-related onshore and offshore facili-
ties Into or upon the navigable waters of
the United States or adjoining shore-
lines.
(b) Except as provided In paragraph
(d) of this section, this part applies to
owners or operators of non-transporta-
tion-related onshore and offshore facili-
ties engaged in drilling, producing, gath-
ering, staring, processing, refining.
transferring, distributing or « As provided in see. 313 (88 Stat.
875) departments, agencies, and instru-
mentalities of the Federal government
are subject to these regulations to the
same extent as any person, except for the
provisions of i 112.8.
(d) This part does not apply to:
(1) Facilities, equipment or operations
which are not subject to the jurisdiction
of the Environmental Protection Agency.
as follows:
(A) onshore and offshore facilities,
which, due to their location, could not
'reasonably be expected to discharge oil
into, or upon the navigable waters of
the1 United States or adjoining shore-
Tines. This determination shall be based
solely upon a consideration of the geo-
graphical, locattonal aspects of the facil-
ity (such as proximity to navigable
waters or adjoining shorelines, land con-
tour, drainage, etc.) and shall exclude
consideration of manma/ie features such
as dikes, equipment or other structures
which may serve to restrain, hinder, con-;
tain or otherwise prevent a discharge o»
oil from reaching navigable waters of the
United States or adjoining • shorelines:
(B) equipment or operations of vessels
or transportation-related onshore and
offshore facilities' which are subject to
authority and control of the Department
of Transportation, as .defined in the
Memorandum of Understanding between
the Secretary of Transportation and the
Administrator of the Environmental Pro-
tection Agency, dated November 24,1971.
36 FR 24000.
(2) those facilities which, although
otherwise subject to the jurisdiction of
the Environmental Protection Agency,
meet both of the following requirements:
(A) the underground buried storage
capacity of the facility is 42.000 gallons
or less of oil. and
(B) the storage capacity, which is not
buried, .of the facility is 1.320 gallons
or less of oil, provided no single container
has a capacity in excess of 660 gallons.
[41 FR 12657, March 26, 1976]
(e> This part provides for the prepara-
tion and implementation of Spill Pre-
vention Control and Countermeasure
Plans prepared in accordance with
9112.7. designed to complement existing
laws, regulations, rules, standards, poli-
cies and procedures pertaining to safety
standards, fire prevention and pollution
prevention rules, so as to form a compre-
hensive balanced Federal/State spin pre-
vention program, to mtn
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131:0932
FEDERAL REGULATIONS
ance used, or capable of bring used as
a means at transportation on water.
other than a public vesseL
§ 112^ Remuremena for preparation
and implementation of Spill Preven-
tion Control and Councermeaiare
Piano.
'a) Owners or operators of onshore
and offshore facilities in operation on or
before the effective date of this part that
have discharged or, due to their loca-
tion, could reasonably be expected to
discharge oil In" harmful quantities, as
defined in 40 CFR Part 110. into or upon
the navigable waters of the United States
or adjoining shorelines, shall prepare a
Spin Prevention Control and Counter-
measure Plan (hereinafter "SPCC
Plan"), in writing and in accordance with
section 112.T. Except as provided for in
paragraph of this section, such SPCC
Plan shall be prepared within six months
after the effective date of this part and
shall be fully implemented as soon as
possible, but not later than one rear after
the effective date of this part.
[41 FR 12657, March 26, 1976]
(b) Owners or operators of onshore
and offshore facilities that become op-
erational after the effective date of »I<-T
part, and that have discharged or could
reasonably be expected to discharge oil
in harmful quantities, as defined in 40
CFR Part 110, into or upon the navigable
waters of the United States or adjoining
shorelines, shall prepare an SPCC Plan
in accordance with 5112,7. Except as
provided for in paragraph (f) of this sec-
tion, such SPCC Plan «hnii be prepared
within six months after the date such
facility begins operations and shall be
fully implemented as soon as possible.
but not later <*«•» one year after such
facility begins operations.
(c) Owners or operators of onshore
*n«< offshore mobile or portable facilities,
such as onshore drilling or workover rigs.
barge mounted offshore drilling or work-
over rigs, and portable fueling facilities
shall prepare and implement an SPCC
Plan as required by paragraphs (a), (b)
and of this section. The owners or
operators of such faculty need not pre-
pare a new SPCC Plan each time the
facility is moved to a new site. The SPCC
Plan may be a general plan, prepared in
accordance with section 112.7, using good
engineering practice. When the mobile or
portable facility is moved. It must be lo-
cated and installed using the spill pre-
vention practices outlined in the SPCC
Plan for the facility. No moot: or port-
able facility subject to this regulation
shall operate unless the SPCC Plan has
been implemented. Ths SPCC Plan "shall
only apply while the facility is in a IseJ
• non-transportation) operating mode.
[41 FR 12657. March 26, 1976]
(d) No SPCC Plan shall be effective
to satisfy the requirements of this part
nniaw it has been reviewed by a Regis-
tered Professional Engineer and certi-
fied .to by such Professional Engineer.
By m^rn of this certification the en-
gineer, having examined the facility and
being familiar with the provisions of this
part, shall attest that the SPCC Plan has
been prepared in accordance with good
engineering practices. Such certification
shall In no way relieve the owner or op-
erator of an onshore or offshore facility
of his duty to prepare and fully imple-
ment such Plan in accordance with
3112.7, as required by paragraphs (a).
(b) and (c) of this section.
(e) Owners or operators of a facility
for which an SPCC Plan is required pur-
suant to paragraphs (a), (b) or (c) of
this section shall maintain a complete
copy of the Plan at such facility if the
facility is normally attended at least 3
hours per day, or at the nearest field
office if the facility is not so attended.
and «*"*ii pig>a such Plan available to
the Regional Administrator for on-site
review during normal working hours.
(f) Extensions of time.
(1) The Regional Administrator may
authorize an extension of time for the
preparation and full implementation of
an SPCC Plan beyond the time permitted
for the preparation and implementation
of an SPCC'Plan pursuant to paragraphs
(a), (b) or (c> of this section where he
finds that the owner or operator of a
facility subject to paragraphs (a), (b)
or (c) of this section cannot fully com-
ply with the requirements of this part
as a result of either nonavailability of
qualified personnel, or delays in con-
struction or equipment delivery beyond
the control and without the fault of such
owner or operator or their respective
agents or employees.
(2) Any owner or operator seeking an
extension of time pursuant to paragraph
(f) (1) of this section may submit a letter
of request to the Regional Administrator.
Such letter shall include:
(i) A complete copy of the SPCC Plan,
if completed:
(il> A full explanation of the cause for
any such delay and the specific aspects
of the SPCC Plan affected by the delay;
(ill) A full discussion of actions being
taken or contemplated to minimize or
mitigate such delay;
(iv) A proposed time schedule for the
implementation of any corrective actions
being taken or contemplated, including
interim dates for completion of tests or
studies, installation and operation of any
necessary equipment or other preventive
measures.
In addition, such owner or operator may
present additional oral or written state-
ments in support of his letter of request.
(3) The submission of a letter of re-
quest for extension of Mm« pursuant to
paragraph (f) (2) of this section shall In
no way relieve the owner or operator
from his obligation to comply with the
requirements of 3 112.3 (a), (b) or (c).
Where an extension of time is authorized
by the Regional Administrator for par-
ticular equipment or other specific as-
pects of the SPCC Plan, such extension
shall in no way affect the owner's or op-
erator's obligation to comply with the
requirements of 3112.3 (a), (b) or (c)
with respect to other equipment or other
specific aspects of the SPCC Plan for
which an extension of time has not been
expressly authorized.
Environment Reporter
40
§ 112.4 Amendment of SPCC Plan* by
Regional Administrator.
(a) Notwithstanding compliance with
§ 112.3, whenever a faculty subject to
3 112.3 (a) , (b) or (c) has: Discharged
more than 1.000 U.S. gallons of oil into
or upon the navigable waters of the
United States or adjoining shorelines in
a single spill event, or discharged oil in
harmful quantities, as defined in 40 CFR
Part 110. into or upon the navigable
waters of the United States or adjoining
shorelines in two spill events, importable
under section 311 (b) (.5) of the FWFCA.
occurring within any twelve month pe-
riod. the owner or operator of such fa-
cility «rmn submit to t*r> Regional Ad-
ministrator, within 60 days from the fc*m*
such facility becomes subject to this sec-
tion. the following:
(1) Name of the facility;
(2) Name(s) of the owner or operator
of the facility;
(3) Location of the facility:
(4) Date and year of initial faculty
operation;
(5) ttfa-Trfrnmn storage or fraTTfT^g ca—
paclty of the facility "Bd normal daily
(6) Description of the facility, includ-
ing maps. Sow diagrams, «"d topograph-
ical maps:
(7) A complete copy of the SPCC Plan
with any amendments;
(8) The cause(s) of such spill, includ-
ing a failure analysis of system or sub-
system in which the failure occurred;
(9) The corrective actions and/or
countermeasures taken. Including an
adequate description of equipment re-
pairs and/or replacements;
(10) Additional preventive measures
taken or contemplated to minimize the
possibility of recurrence;
(11) Such other Information as the
Regional Administrator may reasonably
require pertinent to the Plan or spill
event.
(b) Section 112.4 shall not apply until
the expiration of the time permitted for
the preparation and implementation of
an SPCC Plan pursuant to 5 112.3 (a),
(b),(c) and(f).
(c) A complete copy of all information
provided to the Regional Administrator
pursuant to paragraph (a) of this section
shall be sent at the same time to the
State agency in charge of water pollu-
tion control activities in and for the
State in which the faculty is located.
Upon receipt of such information such
State agency may conduct a review and
make recommendations to the Regional
Administrator as to further procedures,
methods, equipment and other require-
ments for equipment necessary to pre-
vent and to contain discharges of oil
from such facility.
(d) After review of the SPCC Plan for
a facility subject to paragraph (a) of
this section, together with all other in-
formation submitted by the owner or
operator of such facility, and by the
State agency under paragraph (c) of
this section, the Regional Administra-
tor may require the owner or operator
of such facility to amend the SPCC Plan
if he fl"d« that the Plan does not meet
the requirements of this part or that
tee amendment of the Plan is neces-
[S«c.
-------
OIL POLLUTION PREVENTION
S-314
131:0933
sary to prevent and to contain discharges
of oil from such facility.
. (e) When the Regional Administra-
tor proposes to require an.amendment to
*>*• SPCC Plan, he «hail yMfy *>!• fa-
cility operator by certified mail addressed
to, or by personal delivery to, the faculty
owner or operator, that he proposes to
require an Plan, and
shaii specify *n* terms of such amend-
ment. If the facility owner or opera-
tor is a corporation, a copy of such
notice «ha-fl also be mailed to the regis-
tered agent, if any, of such corporation
in the State where such facility is lo-
cated. Within 30 days from receipt of
such notice, the facility owner or opera-
tor may submit written information.
views, and arguments on tfr*» aTTM^riTn^m,
After considering all relevant material
presented, the Regional Administrator
shall notify the facility owner or opera-
tor of any **n+nfirn**it required or shall
rescind the notice. The amendment re-
quired by the Regional Administrator
-«haJi become part of the Plan 30 days
after such notice, unless the Regional
Administrator, for good cause, shall
specify another effective date. The owner
or operator of the facility shall imple-
ment tfr* afjfl»firfTfl»nt of t^<* Plan as soon
as possible, but not later than six
months after ^ft tLmm^f^mafnt becomes
part of the Plan. imi«« the Regional Ad-
ministrator specifies another date.
An ostner or operator may appeal
a decision made by the Regional Admin-
istrator requiring an amendment to an
SPCC Plan. The-appeal shall be made to
the Administrator of the United States
Environmental Protection . Agency and
must be made in writing within 30 days
of receipt of the notice from the-Regional
Administrator requiring the amendment.
A complete copy of tbe appeal must be
sent to the Regional Administrator at the
time tbe appeal is made. The appeal shall
contain a clear and concise statement of
the issues and points of fact in tbe case.
It may also contain additional informa-
tion from the owner or operator, or from
any other person. The Administrator or
his designee may request additional in-
formation from tbe owner or operator.
or from any other person. The Adminis-
trator or his designee shall render a de-
cision within 60 days of receiving tbe ap-
peal and shall notify the owner or oper-
ator of his decision.
[41 FR 12657, March 26, 1976]
• § 112^ Amendment -of Spill Prevention
Control and Coontenneasure Plan* by
owners or operators.
(a) Owners or operators of faculties
subject to } 112J (a). (b) or (c) shaD.
amend the SPCC Plan for such facility
in accordance with 5112.7 whenever
there is a change in facility "*" be effective to satisfy the require-
ments of this section ««i»«« it has been
certified by a Professional Engineer in
accordance with 9112.3 (d).
§ 112.6 Gvil penalties for violation of
Oil Pollution Prevention Regulation*.
Owners or operators ot facilities sub-
ject to 1112.3(a), (b) or (c) who violate.
the requirements of this Part 112 by
failing -r refusing to comply with any of
the provisions of 3112-.3. ! 112.4 or
5112 J «n».n be liable for a civil penalty of
not more than $3,000 for each day such
violation ^TI**""** ClvH penalties «*">n
be imposed in accordance with proce-
dures set out in Part 114 of this sub-
chapter O.
§ 112.7 Guidelines 'for the preparation
and implementation of a Spill Pre-
vention Control and Coanlermeasnre
Plan.
The SPCC Plan shall be a carefully
thought-out plan, prepared in accordance
with good engineering practices, and
which has the full approval of manage-
ment at a level with authority to com-
mit the necessary resources. If the plan
«*it« for additional fn^Wtlr? or proce-
dures. methods, or equipment not yet
fully operational, these items should be
discussed in separate paragraphs, and
the details of installation
-------
131:0934
FEDERAL REGULATIONS
the event of an uncontrolled spin, return
the oil to toe plant.
• (7> Where drainage waters are treated
in more than one treatment unit, nat-
ural hydraulic Sow should be used. If
pump transfer Is needed.' two "lift"
pumps should be provided, and at least
one of the pumps should be permanently
installed when such treatment is con-
tinuous. In any event, whatever tech-
niques are used facility drainage systems
should be adequately engineered to pre-
vent oil from reaching navigable waters
In the event of equipment failure or
human error at the facility.
(2) Bulk storage tanks (onshore); (ex-
cluding production facilities). (1) No
tank should be used for the storage of
oil '^pigg* its material *n>* construction
are compatible with the material stored
and conditions of storage such as pres-
sure «"d temperature, etc.
(11) All bulk storage tank installations
should be constructed so that a second-
ary means of containment Is provided for
the entire contents of the largest single
tank plus sufficient freeboard to allow
for precipitation. Diked areas should be
sufficiently impervious to contain spilled
oil. Dikes, containment curbs, and pita
are commonly employed for this purpose.
but they may not always be appropriate.
An alternative system could consist of a
complete drainage trench enclosure ar-
ranged so that a spill could terminate
and be safely confined in an in-plant
catchment basin or holding pond.
(ill) Drainage of rainwacer from the
diked area into a storm drain or an efflu-
ent discharge that empties into an open
water course, lake, or pond, and bypass-
ing the in-plant treatment system may
be acceptable if:
(A) The bypass valve is normally
sealed closed.
(B) Inspection of the run-off rain
water ensures compliance with appli-
cable water quality standards and will
not cause a harmful discharge as denned
in 40 CFR 110.
AH aboveground valves and pipe-
lines should be subjected to regular ex-
aminations by operating personnel at
which time the general condition of
items, such as flange joints, expansion
joints, valve glands and bodies, catch
pans, pipeline supports, locking of valves.
and metal surfaces should be assessed. In
addition, periodic pressure testing may
be warranted for piping in areas where
facility drainage is such that a failure
might lead to a spill event.
(v) Vehicular traffic granted entry into
the facility should be warned verbally
or by appropriate signs to be sure that
the vehicle, because of its size, will not
endanger above ground piping.
(4) Facility tank car and tank truck
loading/unloading rack (onshore). (1)
Tank car and tank truck loading/un-
loading procedures should meet the min-
imum requirements ""1 regulation estab-
lished by the Department of Transpor-
tation
(11) Where rack area drainage does
not flow into a catchment basin or treat-
ment facility designed to handle spills, a
quick drainage system should be used for
tank truck loading and unloading areas.
The containment system should be de-
signed to hold at least maximum capacity
of any single compartment of a tank car
or tank truck loaded or unloaded In the
plant.
(ill) An interlocked warning light or
physical barrier system, or warning
signs, should be provided in loading/un-
loading areas to prevent vehicular de-
parture before complete disconnect of
flexible or fixed transfer 'in»«.
(iv> Prior to filling and departure of
any tank car or tank truck, the lower-
most drain and all outlets of such, ve-
hicles should be closely examined for
leakage, and if necessary, tightened, ad-
justed, or replaced to prevent liquid
leakage while in transit.
(3) Oil production facilities (onshore).
(1) Definition. An onshore production fa-
culty may include all wells, flowlines,
separation equipment, storage facilities,
gathering lines, and auxiliary non- trans-
portation-related equipment and facili-
ties in a single geographical oil or gas
field operated by a single operator.
(11) Oil production facility (onshore)
drainage. (A) At tank batteries and cen-
tral treating stations where an acci-
dental discharge of oil would have a
reasonable possibility of reaching navi-
gable waters, the dikes or equivalent re-
quired under 5112.7(c)(l) should have
drains closed and sealed at all times
except when rainwater is being drained.
Prior to drainage, the diked area should
be Inspected as provided in paragraph
(e>(2)(ui) (B), C), and (D). Accumu-
lated oil on the rainwater should be
picked up and returned to storage or dis-
posed of in accordance with approved
methods.
(3) Field drainage ditches, roeo
ditches. ""* oil traps, sumps or skim-
mers, if such exist, should be Inspected
at regularly scheduled intervals for ac-
cumulation of oil that may have escaped
from small leaks. Any such accumula-
tions should be removed.
(ill) Oil production facility (onshore)
ouflfc storage tanks. (A) No tank should
be used for the storage of oil unless its
material and construction are compati-
ble with the material stored and the
conditions of storage.
(SM. m.7(eM5Hiii)]
-------
OIL POLLUTION PREVENTION
3-!3t
131:0935
(B) All tank battery and central treat-
ing p1*"1* truttaiiaMMTM «houirf be provided
with a secondary mpans of containment
tar the entire contents of the largest sin-
gle famfe if feasible, or alternate systems
such as those outlined in 5 112.7(c) (1).
Drainage from undiked areas should be
safely confined in a «itotmt»nt t»g«rt sumps are not practicable
oil contained in collection equipment
should be removed as often as necessary
to prevent overflow.
(ill) For facilities employing a sump
system, sump and drains should be ade-
quately sized and a spare pump or equiv-
alent method should be available to
remove liquid from the sump and assure
that oil does not escape. A regular sched-
uled preventive maintenance inspection
and testing program should be employed
to assure reliable operation of the liquid
removal system and pump start-up de-
vice. Redundant automatic sump pumps
and control devices may be required on
some installations.
(lr) In areas where separators and
treaters are equipped with dump valves
whose predominant mode of failure Is in
the closed position and pollution risk is
high, the facility should be specially
equipped to prevent the escape of oil.
This could be accomplished by extending
the flare line to a diked area if the sepa-
rator is near shore, equipping it with a
high liquid level sensor *hp^ will auto-
matically shut-in wells producing to the
separator, parallel redundant dump
valves, or other feasible alternatives to
prevent oil discharges.
(v) Atmospheric storage or surge tanks
should be equipped with high liquid level
sensing devices or other acceptable al-
ternatives to prevent oil discharges.
(vl) Pressure tanks should be equipped
with high and low pressure sensing de-
vices to activate an alarm and/or con-
trol the flow or other acceptable alterna-
tives to prevent oil discharges.
(vil) Tanks should be equipped with
suitable corrosion protection.
(viil) A written procedure for inspect-
ing and testing pollution prevention
equipment and systems should be pre-
pared and maintained at the facility.
Such procedures should be included as
part of the SPCC Plan.
(ix) Testing and inspection of the pol-
lution prevention equipment and systems
at the facility should be conducted by the
owner or operator on a scheduled peri-
odic basis commensurate with the com-
plexity, conditions ftrvl ^pMiimgEanr**^ of
the facility or other appropriate regula-
tions.
(x) Surface and subsurface well shut-
in valves and devices in use at the facil-
ity should be sufficiently described to
determine method of activation or con-
trol, e.g.. pressure differential, change in
fluid or flow conditions, combination of
pressure and flow, manual or remote con-
trol mffttantmat Detailed records for
each well, while not necessarily part of
the plan should be kept by the owner or
operator.
(3d) Before drilling below any '•q-g'yg
string. «"""1 during workover operations
a blowout preventer (BOP) assembly and
well control system should be installed
that is capable of controlling any well-
head pressure that is expected to be en-
countered while that BOP assembly is
on the well. Casing and BOP Installations
should be in accordance with State reg-
ulatory agency requirements.
(jdi) Extraordinary well control meas-
ures should be provided should emer-
gency conditions, including fire, loss of
control and other abnormal conditions.
occur. The degree of control system re-
dundancy should vary with hazard ex-
posure and probable consequences of
failure. It is recommended that surface
shut-in systems have redundant or "fail
close" valving. Subsurface safety valves
may not be needed in producing wells
that will not flow but should be installed
as required by applicable State regula-
tions.
(xiil) In order that there will be no
misunderstanding of joint and separate
duties and obligations to perform work
in a safe and pollution free manner.
written instructions should be prepared
by the owner or operator for contractors
and subcontractors to follow whenever
contract activities Include servicing a
well or systems appurtenant to a well or
pressure vessel. Such instructions and
procedures should be maintained at the
offshore production facility. Under cer-
tain circumstances and conditions such
contractor activities may require the
presence at the faculty of an authorized
representative of the owner or operator
who would Intervene when necessary to
prevent a spill event.
(xiv) All manifolds (headers) should
be equipped with check valves on indi-
vidual flowlines.
(xv) If the shut-in well pressure is
greater i**** the working pressure of the
flowllne and manifold valves up to and
inHiiHing the header valves associated
with that individual flowllne. the flow-
line should be equipped with a high pres-
sure sensing device and shutin valve at
the wellhead "r»i«"» provided with a pres-
sure relief system to prevent over pres-
suring.
(xvl) AH pipelines appurtenant to the
facility should be protected from corro-
sion. Methods used, such as protective
coatings or cathodic protection, should
be discussed.
(xvii) Sub-marine pipelines appurten-
ant to the facility should be adequately
protected against environmental stresses
and other activities such as filing
operations.
(xviil) Sub-marine pipelines appurten-
ant to the facility should be in good
Copyright <£ 1973 by Th« Bureau of National Affairs, Inc.
43
-------
131:0936
FEDERAL REGULATIONS
ope7atin£ condition at nil times and in*
spected on a scheduled periodic basis for
failures. Such inspections should be
documented arvi ^<\ipta^pi»rf at t2ie
facility.
(8) Inspections and records. Inspec-
tions required by this part should be in
accordance with written procedures de-
veloped for the facility by the owner or
operator. These written procedures and
a record of the inspections, signed by the
appropriate supervisor or inspector.
should be made part of the SPCC Plan
and maintained for a period of three
years.
(9) Security (excluding oil -production
facilities). (1) All plants handling, proc-
essing, and storing oil should be fully
fenced, and entrance gates should be
locked and/or guarded when the plant
is not in production or is unattended.
(11) The master flow and drain valves
and any other valves that* will permit
direct outward flow of the tank's con-
tent to the surface should be securely
locked in the closed position when in
non-operating or non-standby status.
(ill) The starter control on all oil
pumps should be locked in the "off"
position or located at a site accessible
only to authorized personnel when the
pumps are in a non-operating or non-
standby status.
(iv) The 'loading/unloading connec-
tions of oil pipelines should be securely
capped or blank-flanged when not in
service or standby service far an ex-
tended time. This security practice
should also apply to pipelines that are
emptied of liquid content either by
draining or by inert gas pressure.
(v) Facility lighting should be com-
mensurate with the type and location of
the facility. Consideration should be
given to: (A) Discovery of spills oc-
curring during hours of darkness, both
by operating personnel, if present, and
by non-operating personnel (the gen-
eral public, local police, etc.) and (B)
prevention of spills occurring through
acts of vandalism.
(10) Personnel, training and rpitt
prevention procedures. (1) Owners or op-
erators are responsible for properly In-
structing tnrtr personnel in the operation
and ""*|"**T«TIM» of equipment to pre-
vent the discharges of oil and applicable
pollution control laws, rules and regula-
tions.
(11) Tftyh applicable facility should
have a designated person who is account-
able for oil spill prevention and who re-
ports to line Tran ^np**** **r *
(UD Owners or operators should
schedule and conduct spill prevention
briefings for their operating personnel
at Intervals frequent enough to assure
adequate understanding of the SPCC
Plan for that facility. Such briefings
highlight "J"< describe known
spill events or failures, malfunctioning
components, and recently developed pre-
cautionary measures.
Memorandum, of Understanding between
the Secretary ot Transportation and the Ad-
ministrator at che Environmental Protection
Agency.
section n—ocrnvrrtONs
The Environmental Protection Agency and
the Department of Transportation agree that
for the purposes of Executive Order 11S48.
the. term:
(1) "Non-transportation-related onshore
and offshore faculties" means:
(A) Fixed onshore and offshore ou well
drilling facilities Including all equipment
and appurtenances related thereto used In
drilling operations for exploratory or develop-
ment wells, but excluding any terminal facil-
ity, unit or process integrally associated with
the handling or transferring of oil la bulk to
or from a vessel.
(B) Mobile onshore and offshore ou veil
drilling platforms, barges, trucks, or other
mobile facilities Including ail equipment and
appurtenances related thereto when such
mobile facilities are fixed la position for the
purpose of drilling operations for exploratory
or development wells, but excluding any ter-
minal facility, unit or process integrally as-
sociated with the handling or transferring of
oil In bulk to or from a vessel.
(C) fixed onshore and offshore oil produc-
tion structures, platforms, derricks, and rigs
including all equipment and appurtenances
related thereto, ai well as completed wells
and the wellhead separators, oil separators.
and storage facilities used In the production
of oil. bus excluding any terminal facility,
unit or process Integrally associated with
the handling or transferring of oil In bulk
to or from a vessel.
(D) Mobile onshore and offshore oil pro-
duction facilities Including all equipment
and appurtenances related thereto as well
as completed weus and wellhead equipment.
piping from wellheads to oil separator!, oil
separators, and storage facilities used tn the
production of oil when such mobile facilities
are axed In position for the purpose of oil
production operations, but excluding any
terminal facility, unit or process Integrally
associated with the handling or transferring
of oil in bulk to or from a vessel.
(Z) OU refining facilities Including all
equipment and appurtenances related
thereto as well as tn-plant processing unit*.
storage units, piping, drainage systems and
wane treatment unit* used la the refining
of ou. bat excluding any terminal facility.
unit or process Integrally associated with the
handling or transferring ot oil In bulk to or
from a Teasel.
(») OU storage faculties Including all
equipment and appurtenances related
thereto as well as fixed bulk plant storage.
terminal oU storage facilities, consumer stor-
age, pumps and drainage systems used In the
storage of oil. but excluding inline or break-
out storage tank* needed for the continuous
operation of a' pipeline system and any
terminal facility, unit or process Integrally
associated wtth the handling or transferring
of oil in bulk to or from * vessel.
(G) Industrial, commercial, agricultural
or public faculties which use and store oil.
but excluding any terminal facility, unit or
process integrally associated wtth the han-
dling or transferring of oil In bulk to or from
a vessel.
(HI Waste treatment facilities Including
in-plant pipelines, affluent discharge lines.
and storage tanks, but excluding waste treat-
ment facilities located on vessels and termi-
nal storage ranlti and appurtenances for the
reception of oily ballast water or tank wash-
ings from vessels and associated systems used
for off-loading vessels.
(I) Loading racks, transfer hoses, loading
urns and other equipment which are ap-
purtenant to a nontransportatlon-relaud
facility or terminal facility and which are
used to transfer oil In bulk to or from high-
way vehicles or railroad can.
(J) Highway vehicles and railroad cars
which, are used for che transport of oil ex-
clusively within the confines of a aontrans-
portation-related facility and which are not
Intended to transport, oil in interstate or In-
trastate commerce.
(K) Pipeline systems which are used for
the transport of oil exclusively within the
confines of a nontransportatloa-related facil-
ity or terminal facility and which are not In-
tended to transport oil In Interstate or
Intrastate commerce, but excluding pipeline
systems used to transfer oil in bulk to or
from a vessel.
(2) "transportation-related onshore and
offshore facilities" means:
(A) Onshore and offshore terminal facili-
ties Including transfer hoses, loading arms
and other equipment and appurtenances
used for the purpose of handling or trans-
ferring oil- "in bulk to or from a vessel as
well as storage tanks and appurtenances for
the reception of oily ballast water or <•»"*
washings from vessels, but excluding ter-
minal waste treatment facilities and ter-
minal oil storage facilities.
(B) Transfer hoses, loading arms and
other equipment appurtenant to a non-
transportation-related facility which is used
to transfer oU in bulk to or from a vessel.
(C) Interstate and Intrastate onshore and
offshore pipeline systems including pumps
and appurtenances related thereto as well
as In-line or breakout storage tanks needed
for the continuous operation of a pipeline
system, and pipelines from onshore and off-
shore oil production facilities, but excluding
onshore and offshore piping from wellheads
to oU separators and pipelines which are
used for the transport of oil exclusively
within the confines of a nontransportation-
related facility or terminal facility and
which are not Intended to transport oU la
interstate or Intrastate commerce or to
transfer oil In bulk to or from a vessel.
(D) Highway vehicles and railroad cars
which are used for the transport of ou In
interstate or Intrastate commerce and the
equipment and appurtenances related
thereto, and equipment used for the fueling
of locomotive units, as well as the nghts-
of-way on which they operate. Excluded are
highway vehicles and railroad cars and mo-
tive power used exclusively within the con-
fines of a aontransportatlon-related facility
or terminal facility and which are aot in-
tended for use la interstate or latrastate
commerce.
Environment Reporter
44
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S-219
131:0971
EPA INTERIM REGULATIONS ON CIVIL PENALTIES
FOR VIOLATIONS OF OIL POLLUTION PREVENTION REGULATIONS
(40CFR 114; 39 FR 31602, August 29, 1974)
Title 40— Protection of Environment
CHAPTER I— ENVIRONMENTAL
PROTECTION AGENCY
[7BL 330-3]
PART 114 — CIVIL PENALTIES FOR VIOLA-
TION OF OIL POLLUTION PREVENTION
REGULATIONS
Interim Regulation
ATTHOwrr: Sea. 311 (J). 501 (a.). Pub. L»w
92-400, 88 Stai. 868, 880 (33 U.S.C. 1331 (J),
NON-THANSPORTATlOir RSLATXB ONSHORE
ABO OITSEORZ P*.«!II.ITIKS
§ 114.1 General applicability.
Owners or operators of faculties sub-
ject to 9 112.3 (a) , (b) or (c) of this sub-
chapter who violate the requirements of
Part 112 of this Subchapter O by failing
or refusing- to comply with any of the
provisions of 5112.3, 112.4. or 112.5 of
this subchapter shall be liable for a civil
penalty of not more than $5,000 for each
day such violation continues. Civil pen-
alties shall be assessed and compromised
in accordance with this Part. No penalty
«h«n be assessed until the owner or oper-
ator shall have been given notice and
an opportunity for hearing hi accord-
ance with this Part.
§ 114.2 Violation.
Owners or operators of facilities shall
be liable for a civil penalty for non-
compliance with the requirements of
Part 112 of this subchapter. Including
but not limited to failure to?
(a) Prepare a Spill Prevention Con-
trol and Countermeasure (SPCC) plan
in accordance with 9 112.3 of this sub-
chapter:
(b) Eave a SPCC plan certified by a
Registered Professional Engineer as re-
quired by 9 112J of this subchapter;
(c) Implement the SPCC plan as re-
quired by 9 112.3 of this subchapter;
(d) Submit Information after a spill
as required by 9 112.4 of this subchapter:
(e) Amend plan as required by i 112.4
of this subchapter:
(f) Implement amendment as required
by 5 112.4 of this subchapter;
(g) Amend plan after change In fa-
cility design as required by 5 112.8 of
t>ii« subchapter;
(h) Review plan every three years as
required by 9 112.5 of this subchapter:
(1) Amend plan after review as re-
quired by 9 112 .5: or
(J) Have amendment certified as re-
quired by 9 112.5 of this subchapter and
implemented.
§ 114^ Determination of penalty.
Right to request a hearing; and
(h) The procedures for requesting a
hearing including the right to be repre-
sented by counsel,
§ 114.5 Request for bearing.
Within thirty (30) days of the date of
receipt of a Notice of Violation, the per-
son named in the Notice may request a
hearing by submitting a written request
signed by or on behalf of such person by
a duly authorized officer, director, agent,
or attorney-in-fact, to the Regional Ad-
ministrator.
(a) Requests for hearings shall:
(1) State the name and address of the
person requesting the hearing:
(2) Enclose a copy of the Notice of
Violation; and
(3) State with particularity the issues
to be raised by such person at the hear-
ing.
(b) After a request for hearing which
complies with the requirements of para-
graph (a) of this section has been filed,
a hearing «M'l be scheduled for the
earliest practicable date.
(c) Extensions of the time for the
commencement of the hearing may be
granted for good cause shown.
§ 114.6 Presiding Officer.
The hearing shall be conducted by the
Presiding Officer. The Regional Adminis-
trator may designate any attorney in the
Environmental Protection Agency to act
as the Priding Officer. No person sh«H
serve as a Presiding Officer where he has
any prior connection with the case in-
cluding without limitation the perform-
ance of investigative or prosecuting func-
tions or any other such functions. The
Presiding Officer appointed -«h»n have
the full authority to conduct the hearing.
decide issues and to assess a civil penalty
as appropriate.
§ 114.7 Consolidation.
The Presiding Officer may, in his dis-
cretion, order consolidation of any hear-
ings held under this Part and arising
within one Region whenever he deter-
mines that consolidation will expedite or
simplify the consideration of the issues
presented. The Administrator may. in
his discretion, order consolidation, and
designate one Region to be responsible
for the conduct of any hearings held un-
der this Part which arise in different
Regions whenever he determines that
consolidation will expedite or simplify
the consideration of the Issues presented.
Consolidation shall not aSect the right
of any person to raise issues that could
have been raised if consolidation had not
occurred. At the conclusion of the hear-
ing the Presiding Officer shall render a
separate decision for each separate civil
penalty case.
§114.8 Preparing conference.
The Presiding Officer may hold one or
more prehearing conferences and may
issue a hearing agenda which may in-
clude, without limitation, decisions with
regard to any or all the following:
(a) Stipulations and admissions;
(b) Disputed issues of fact;
(c) hearing procedures including sub-
mission of oral or written testimony and
the time allotted for oral arguments; and
(d) any other matter which may ex-
pedite the hearing or aid in disposition
of any issues raised therein.
§ 114.9 Conduct of hearing.
The hearing shall be held in the gen-
eral location of the facility where the
alleged violation occurred or as agreed
to by EPA and the person charged. The
Copyright
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131:0972
FEDERAL REGULATIONS
Presiding Officer shall have the duty to
conduct a fair and impartial hearing.
to take action to avoid unnecessary delay
in the disposition of proceedings, and to
m?tn»-ajn order. The person charged with
the violation may offer relevant facts.
statements, explanations, and other
items which such person feels should be
considered in defense to the charges,
bearing on the person's efforts to achieve
compliance after notification of the vio-
lation or which may bear upon the pen-
alty to be assessed. The EPA or other ap-
propriate Agency personnel shall have
the opportunity to offer facts, statements,
explanations and other items including
testimony of other appropriate Agencies
personnel in order for the Presiding
Officer to be fully informed. In the event
the matter cannot be resolved by settle-
ment the person charged with the viola-
tion shall be informed in writing, of the
decision of the Presiding Officer ar"1 ?hal1
be advised of his right to appeal.
§ 114.10 Decision.
Within thirty (30) days after the con-
clusion of the hearings, the Presiding
Officer shall issue findings with respect
to the matter, including, where appro-
priate to the amount of the civil penalty.
In assessing the civil penalty the Pre-
siding Officer shall consider the factors
set forth in i 114.3. A copy of the Pre-
siding Officer's decision shall be sent to
the person charged in the Notice of Vio-
lation. The decision of the Presiding Of-
ficer shall become the final decision of
the Environmental Protection Agency
unless within fifteen (15) days from the
date of receipt of such decision, the per-
son assessed the penalty appeals the de-
cision to the Administrator, or ""i«*re the
Administrator shall have stayed the ef-
fectiveness of the decision pending re-
view.
§ 114.11 Appeal to Administrator.
(a) The person assessed a penalty in
the Presiding Officer's determination
shall have the right to appeal an ad-
verse decision to the Administrator upon
filing a written Notice of Appeal in the
form required by paragraph (b) of this
section within fifteen (15) days of the
date the receipt of the Presiding Officer's
decision.
(b) The Notice of Appeal shafl:
(1) State the name and address of the
person filing the Notice of Appeal;
(2) Contain a concise statement of
the facts on which the person relies;
(3) Contain a concise statement
the legal basis on which the person re-
lies; and
(4) Contain a concise statement set-
ting forth the action which the person
proposed that the Administrator take.
(c) The Administrator may delegate
this authority to act in a given case.
(d) The Administrator, after a Notice
of Appeal in proper form has been filed.
shall render a decision with respect to
the appeal promptly. In rendering his
decision, the Administrator may adopt,
modify, or set aside the decision of the
Presiding Officer in any respect and shall
include in his decision a concise state-
ment of the basis therefore. The decision
of the Administrator on appeal shall be
effective when rendered.
Environment Reporter
46
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APPENDIX B
NONTRANSPORTATION-RELATED FACILITIES
Nontransportation-related facilities engaged in drilling, • producing,
gathering, storing, processing, refining, transferring, distributing, or con-
suming oil, which could reasonably be expected to discharge oil in harmful
quantities into waters defined as navigable and which have nonburied aggre-
gate storage capacity greater than 1320 gallons or nonburied storage capacity
greater than 660 gallons in a single container, or which have buried storage
capacity in excess of 42,000 gallons are subject to 40CFR Part 112 and must
have an SPCC Plan. Note that 24 full 55-gallon drums make up 1320 gallons.
"Storage" can include oil production equipment such as separators, heaters,
treaters, etc. Therefore, owners and operators of oil production facilities
maintain an SPCC program for their facilities which do not have oil storage
tanks per se.
The following describes the three major facility categories: (1) Onshore
Nonproduction-Related, (2) Onshore Oil/Gas Production and Drilling/Workover,
and (3) Offshore Oil/Gas Production and Drilling/Workover. The sections which
follow describe some of the technical features of typical facilities which may
be encountered by the inspector. There is one major spill prevention area .
which is common to all of them, and that is secondary containment. Various
secondary containment systems are discussed, as are other important spill pre-
vention measures which the inspector should look for.
ONSHORE NONPRODUCTION-RELATED FACILITIES
These facilities include bulk oil storage and distribution (bulk plants
and marketing terminals), some service stations, boat marinas, truck terminals,
refineries, terminals, oil consumers, and any other facilities not related to
oil/gas production.
Bulk oil storage and distribution facilities such as bulk plants frequent-
ly fall under the requirements of 40CFR Part 112 and are characteristic of a
typical nonproduction facility. An example of a bulk plant is shown in Figure
B-l and consists of:
(a) Loading rack area
(b) Unloading area
(c) Storage tanks — underground and aboveground
(d) Office area
47
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UNLOADING
AREAS
CONCRETE
DIKE
SUMP & PUMP
TO TREATMENT^
OR PICK UP
/
V
Fo"
o
:'o
|O
*0
^0
TANKS(4)
*0
'G.
A
%
I?
,;'!
l •.-;
••ftv^r •*/•
.••.*
&
*!
I
. '•••
^ '•'.
?•, W
••f \ • n
* ' > \\
vx »'• •* -*C
X ^ fl\
*\J&
\ 5' 'A
^|~|
•A ^? •*
x^l-^
v» Q • "_•
•^h
UNDERGROUND
TANKS
x x
ir-
»'.•
,i2
.•**
;i
-4:
:%
»'-1l
x s^ ~'4
& .-«
•^N Vlrt
I •« , | »s.
!rrx • rf
Figure B-l. Bulk oil plant—plan view.
48
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(e) Warehouse (used for storing lube oil and other products)
(f) Truck parking
(g) Pumps, valves, piping
These components are interrelated operationally and the entire facility
should therefore be viewed as a system. Even the office area, although not a
source of oil spills, is related to the loading rack area, tanks, etc., and
thus may be a human factor in preventing a spill in these areas. Also, there
are different spill prevention approaches and these may vary from a number of
individual spill prevention structures to a single structure or piece of equip-
ment which can handle the entire facility. Terrain, drainage, existing facil-
ity design, operational characteristics, etc. all impact the final optimum
spill prevention design. It is therefore appropriate to understand the overall
equipment layout and operation of the facility before evaluating the individual
solutions.
For example, a loading area may not, by itself, have any spill containment
and the tanks by themselves do not have any containment, but the runoff from
the facility may flow into a catchment basin which is under the jurisdiction
of the facility. With proper monitoring and control of the basin, this could
be a satisfactory solution. The inspector needs to be careful to not impose
requirements upon the owner of the facility which exceed the minimum as re-
quired by the regulation. This is true for all operators, from the wealthiest
to the poorest, there are economically viable solutions to all problem situa-
tions. If the facility has suffered a triggering spill, the Regional Adminis-
trator may require an amendment necessary to control spills and protect the
environment.
The Loading Rack Area
This area is used to load oil products (diesel fuel, heating oil, gaso-
line, etc.) into tank trucks, and due to its frequent use is very susceptible
to oil spillage. Since most spills are caused by human error, it is recom-
mended that the following preventive measures be taken:
• Electric controls for pumps should either be locked individually or
locked within a cabinet or behind a locked door to prevent the pumps
from being turned on by unauthorized persons.
• Warning signs or obstructions should be used to help prevent trucks
from driving away while the loading hose is connected.
• Instructions need to specify that loading will be accomplished only
while an operator is in attendance at the loading rack.
It must be realized that in spite of these controls, accidents will still
occur. Therefore, secondary containment must be provided so that a spill from
that area will not leave the property, even in adverse weather. Two types of
containment systems are frequently employed: a quick drainage system or diver-
sionary structure which diverts flow to a sump or oil/water separator; or a
49
-------
dike, catchment basin, or containment area. There are other containment con-
figurations, but. most of them are variations in arrangement rather than basic
function. In all cases, the containment volume must be of sufficient size to
hold the largest compartment of the truck which is being loaded, which will
usually vary from 300 to 1200 gallons. The two types of systems are described
in the following paragraphs.
Quick Drainage System—
A quick drainage system is frequently employed on new installations where
it can be built in at the outset. A typical system is shown in Figure B-2 that
shows how runoff from a loading rack will be contained within a curbed area,
which will then divert the flow to drains which are in turn connected to an
CURBED
COLLECTION
AREA
DRAIN
TO TREATMENT, DISCHARGE
OR PICKUP AS APPROPRIATE
SUMP SYSTEM
.TANK
•PUMP
• LEVEL SENSOR
Figure B-2. Quick drainage system.
50
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underground tank, or sump. The underground tank has a volume of sufficient
size to contain the largest compartment of the operator's truck. The oil col-
lected in the sump can be collected and disposed of properly.
This system is rather elaborate, and due to terrain it may be mandatory,
but it does have advantages for the operator, e.g., the system is clean, is
easily maintained, and takes a minimum of aboveground space, which may be
quite valuable. A refinement of this system is to have a roof constructed over
the curbed area which keeps storm runoff out of the collection sump.
Diversionary Structures—
Diversionary structures are any structures which divert flow to another
location where the spilled oil can be collected, contained, and removed prior
to the escape of oil from the facility. An example of a diversionary structure
is shown in Figure B-3. In this case it was impractical to build an underground
collection system; therefore the rack loading site was graded and curbed to
force the runoff into a diked area which was several feet lower in elevation and
was also used to contain the storage tanks. Note that the drain valve must be
kept locked closed.
Figure B-4 shows another configuration whereby runoff from the loading
area (which is inclined) is collected and diverted by gravity to an under-
ground pipe. This proved beneficial to the operator because the installation
was rather simple and a minimum of downtime was needed for construction.
Bulk Oil Storage Tanks
Bulk oil storage tanks are another frequent source of oil spills, and oc-
casionally large oil spills. It is mandatory that aboveground tanks have sec-
ondary containment in the form of retaining walls, berms, dikes, etc., i.e.,
any structure which will keep the contents of the largest tank from leaving
the owner's property.
A typical method for accomplishing this is to surround the tanks with an
earthen dike constructed of selected compactable soil so that it is impervi-
ous to oil. It is important that the dimensions of the dike be clearly speci-
fied in writing (e.g. , "the dike shall have the following minimum inside dim-
ensions: 24 feet by 48 feet by 2 feet high"), or on a drawing. The inspector
may have to check the dimensions and dike volume.
Materials used in construction can be almost anything, so long as they are
relatively impermeable to oil and are structurally adequate to withstand the
hydrostatic forces and the environmental conditions. Material selection and
design of the dike/retaining wall should be specified on the plan and not be
left up in the air. If a concrete retaining wall is specified, it should be
securely anchored to a footing and should have sufficient strength to withstand
the full hydrostatic head. Concrete block wall construction is acceptable for
low walls, but it is highly susceptible to cracking and usually requires peri-
odic caulking or other refurbishment.
Draining from secondary containment areas is usually accomplished by a
pipe which extends through the wall. A positive action (manually operated)
51
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VALVE
IW/LOCK
(NORMALLY
CLOSED)
RACK
LOADING
AREA
-MTMIN. RACK LOADING CONCRETE
SURFACE
CURB
REINFORCED
CONCRETE WALL 12* HIGH
3" MIN SECTION A-A
ROTATED 90° C.C.W.
NOTES:
1. SECONDARY CONTAINMENT IS AREA SHOWN INDICATED BY HEAVY LINE.
2. DIKE AROUND RACK AREA SHALL CAUSE DRAINAGE/SPILLS TO
FLOW INTO TANK CONTAINMENT AREA.
Figure B-3. Secondary containment—loading rack and storage tanks.
52
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01
TRUCK
TRAFFIC
SEE NOTE
\
DRAIN
TO
SUMP v
jr'?*-
6-SEWER PIPE
MIN. 45' LONG
1
\
+-
CURB
X
1 TRUCK
/ / LOADING
/ / AREA
STEEL GRATE
£ * *+. * •-». * ^ • f* •** * j»v *x T
/
Jt
%
\
I •
1
m — UUMUIHO nMor\
~~— ~— ic
•/7
v*^ 1
I
>
-^
ii tj
ONCRETE —
J
FILL PIPES (5) '
(CONCRETE
OR EARTH • \
OPTIONAL )
\r
^» e
^ pi nww
CURB
Amn»
k_
m
a:
0
t
AF
1
23'
•RON
(APPROX)
NOTE:
1. CONTAINMENT AREA IS INDICATED INSIDE HEAVY LINE.
ARROWS SHOW DRAINAGE FLOW DIRECTION.
2. SUMP LOCATED AT END OF SEWER PIPE SUFFICIENT TO
CONTAIN VOLUME OF SINGLE LARGEST COMPARTMENT.
Figure B-4. Diversionary structure for rack loading area.
-------
valve permits only water to be drained by an operator who must see to it that
no oil is released and keep the valve locked when closed. A suitably rigged
red flag should indicate if the valve is open. Other methods of drainage in-
clude pumps that discharge fluids into standby tanks, oil/water separators,
removal of fluids by vacuum trucks, and specially designed valves that allow
water to pass through, but close when a liquid containing hydrocarbons flows
through the valve. These hydrocarbon sensing valves are reported to be expen-
sive, subject to fouling by sand and dirt, and are not recommended. In no case
should flapper valves be utilized for draining secondary containment areas,
since these valves may be subject to sticking open.
The storage tanks themselves need to be in generally good structural con-
dition, i.e., there should be a minimum of corrosion and there should be no
leaking at any of the seams or pipe joints Some older riveted tanks and bolt-
up tanks experience slight weeping at joints with no danger to the equipment.
If the tanks are on supports, the latter should be in sound condition. This
also applies to the piping, pipe supports, and related equipment. Foundations
should also be examined, if possible, for signs of failure.
Unloading Areas
Unloading areas are used to transfer incoming oil products from a tank
truck to the facility, and are usually located not too far from the loading
rack. It is therefore frequently possible to combine the secondary contain-
ment for the unloading area into the rack loading containment system by grad-
ing, drains, curbing, etc. In general, the same spill prevention measures
apply as for the rack loading area. However, there is a distinction between
the two areas which is quite important, i.e., whereas the rack loading area
may be used almost continuously, the unloading area will be used less frequent-
ly (generally once or twice a day). Also, if the proper precautions are taken
in unloading, the chance of human error is greatly reduced. In many older
facilities, or existing facilities which have built-in physical limitations,
operational changes can be made which will reduce the likelihood of an oil •
spill to a low level. Additionally, the operator can provide backup measures
to clean up any oil which might spill, e.g., absorbents (such as straw, "Oil-
sorb"), vacuum equipment, barriers, etc. However, it should be emphasized that
secondary containment should also be utilized in the loading area whenever
practicable.
Miscellaneous Spill Prevention Measures
Many facilities have empty drums, waste oil storage, steam cleaning equip-
ment, and other oil-related equipment, which are oil spill hazards. All this
equipment should be treated in a manner to allow oil to be collected and dis-
posed of properly. To accomplish this easily, it is frequently advantageous
to use a separator on the rack loading area as a collection point. It is im-
portant that the operator not discharge oil on the ground in a random fashion,
where the next rain will carry it off the facility and into a nearby stream.
Bulk plants and similar facilities should implement periodic formal in-
spections of all spill prevention equipment and procedures. These inspections
54
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should be performed at least once a year. A sample "Inspection Record" is
shown in Figure B-5. Informal inspections should be performed daily to weekly
of oil/water separators, locks and other security devices related to spill pre-
vention, structures/tanks, and oil accumulations within secondary containment
enclosures.
ONSHORE OIL/GAS PRODUCTION AND DRILLING/WORKOVER FACILITIES
Production facilities are also required to have spill prevention measures
taken to prevent oil spills from reaching the waters of the U.S. The follow-
ing paragraphs describe some typical onshore production systems and various
spill prevention problems and solutions. As before, the best general solution
is to have adequate secondary containment.
Onshore Production System
A typical onshore production system is shown in Figure B-6 and consists of
wells, well heads, separators, stock tanks, flow treater, salt water pit, salt
water tank, salt water disposal well, and miscellaneous pumps, valves, etc.
There are obviously numerous variations and all of them cannot be described
here; however, as in a multi-lease production system (where it is necessary to
differentiate the ownership of the oil that is being produced), the systems
are usually repetitions of a single system.
With only a few exceptions, large amounts of corrosive salt water are pro-
duced along with the oil and gas. In the production process this water tends
to partially mix with the oil, forming an emulsion. Treatment of the emulsion
is necessary to separate the oil and water so that the oil can be sold and the
water disposed of properly. Heat, gravity, and chemicals are used, individu-
ally or collectively, to accomplish the separation process.
Holding Pits—
In the older oil fields, settling pits were frequently used to complete
the separation process. Fields like this are still in operation but are grad-
ually being phased out, in part due to their being an oil spill hazard. Most
states now prohibit the use of pits except on a temporary, emergency basis.
It is not too unusual to see a pit with the walls eroded to the point that oil
is about to overflow the pit. Therefore, extreme care must be taken by the
operators to ensure that the pit has sufficient freeboard (one foot minimum),
and that oil/water emulsion is not seeping through the wall of the pit (some-
times seepage, once it has started, can only be stopped by lining the pit).
Occasionally, several pits connected in series will be used to improve the sep-
aration process and facilitate oil removal. Since they will all contain salt
water and varying amounts of oil, all the pits need to be sound. If the pit is
used only during "emergencies," then the plan should clearly define what con-
stitutes an emergency, the "normal" condition of the pit or how it will be
maintained to keep it ready for use during an emergency, and the minimum safe
operating standards during the emergency.
Stock Tanks—
Stock tanks should always be provided with secondary containment with a
volume equal to the largest tank plus a reasonable allowance for rainwater.
55
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ANNUAL INSPECTION RECORD
COMMENTS
EQUIPMENT INSPECTION (CONDITION OF EQUIPMENT INSPECTOR'S
DATE INSPECTED METHOD OR ACTION TAKEN) SIGNATURE
01
Figure B-5. Sample inspection record form.
-------
DISPOSAL PIT
SALT WATER TANK
SEPARATORS
STOCK TANKS
.^
. ir/
'.Sf.
'.VT*
...;-:""• •';.*.--?.*-*
Figure B-6. Drainage—oil production system.
57
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Usually, containment is effected by a dike placed around a group of tanks close
together. Water is drained from the diked area by opening a valve (Figure B-7)
or dropping a "swing pipe" (Figure B-8). The valve and pipe are always locked
when closed; when they are open for draining, a suitably rigged red flag should
so indicate..
If more than one stock tank is used, the tanks should be interconnected
such that if overfilling of a tank occurred, the overflow would be absorbed
by the other tanks. This is especially important where oil production rates
are high in relation to the capacity of the tanks, and timing of tank gaugings
becomes critical. In situations like this, additional safeguards such as
high-level sensors/alarms may be needed if it is not practical to increase the
tank capacity to prevent overfilling.
Pumping Units—
A reciprocating pumping unit on an oilwell commonly uses a crank and arm
which drives a "walking" beam which in turn produces an up-and-down motion to
pump oil from down in the well to the surface. The driving rod at the sur-
face is polished such that a stuffing box will seal against the rod and pre-
vent oil from escaping. However, the packing eventually becomes worn and the
gland needs to be re-tightened or the packing replaced. Frequently this is
neglected and the result is oil leakage which may vary from a quart to several
barrels per day. If the pumping unit is near a body of water, a sump system
should be installed as an oil spill prevention measure and, as in all cases,
the oil seals (gland and packing) shall be maintained to a good operating con-
dition. (Note: The sump can frequently be built in near the stuffing box in
a way that will collect mostly oil and very little rainwater.)
Flowlines—
Flowlines (from the wells to the tank battery) are subject to corrosion
of both the inside and outside of the pipes. Flowlines are also susceptible
to damage from vehicles, earth-moving equipment, farming operations, earth/
moving/settling, thermal stresses and vibration. Also, flowlines are, in the
majority of cases, not visible. They are either intentionally buried for
protection, or they are covered up by nature. Sometimes they are on top of
the ground, but shrubs, vines, grass, etc., obscure them. It is therefore in
most cases almost impossible to inspect a flowline to determine its condition
before a failure occurs.
If an operator has uninspectable flowlines, he should develop and utilize
a preventive maintenance program which includes testing, failure prediction
analysis, and recommendations for temporary repair and permanent replacement.
The operator should make this a priority item and stay ahead of the problem.
Separators and Heater/Treaters—
Separators, heater/treaters, and other process equipment should be pro-
vided with secondary containment whenever practical. The means for accom-
plishing containment are similar to those, discussed for "Stock Tanks." It is
often possible, if the terrain allows, to divert the flow from the area around
the separators to the tank dike area. It may not be advisable to collect oil
right at the heater/treater. The flow can often be diverted to another loca-
tion to avoid creating a fire hazard. Typically, the separators and treaters
58
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DIKE
NORMALLY
CLOSED
Figure B-7. Drain valve.
FLOW-
DIKE
%^MP
J.T -^ft;
.«** *»i »^..
J;^-» . *« -*i . . ,-*v^'«t^
»• 1 '^f£t > .N*7^*..!
%^f\ - *
.g>^».•<•'./ ^J >
ROUND PLATE
(WATER STOP)
^J!
POST
X
5««i*_
^
Figure B-8. "Swing pipe" drain (in closed position)
59
-------
are small compared with the stock tanks, and are easier .to inspect and main-
tain than flowlines. It is possible to establish an effective" monitoring and
failure prevention program and contingency plan that can provide a reasonable
degree of spill prevention for the separators and heater/treaters which some-
times cannot, practically, be afforded secondary containment. Contingency
plans should only be used in those situations where it is impractical to
build secondary containment for a facility.
Onshore Drilling/Workover Facilities
Secondary containment shall be installed around the appropriate area of
each rig to prevent oil (crude, oily drilling fluids, fuels) from reaching
navigable water. Since most drilling rigs use diesel fuel or gasoline as an
energy source for the prime mover, the volume of the secondary containment
must be at least large enough to contain the fuel tank(s) plus rainwater. If
drain valves are used, they shall normally be locked closed as indicated
previously.
A blowout prevention (BOP) assembly shall be used that is capable of
withstanding the full pressure that the well can develop. Most oil-producing
states have requirements for installation of BOP stacks.
OFFSHORE OIL/GAS PRODUCTION AND DRILLING/WORKOVER FACILITIES
Offshore Production Facility
A typical offshore oil production facility is shown in Figure B-9, and
consists of the following basic equipment: wellhead, flowlines, risers, mani-
folds, storage tanks, separators, heater/treaters, and an oil collection sys-
tem. Applicable parts of 40CFR Part 112 are discussed in the following
paragraphs.
Facility Drainage—
Normally, for an offshore facility it is not practical to have secondary
containment that is of sufficient volume to contain "the largest single tank."
Therefore, other measures need to be employed that will reduce the risk of
oil pollution to a minimum practicable level.
One of the most important spill prevention measures that must be utilized
is a collection system for drips, leaks, and spillage of oil on offshore plat-
forms. The collection system can be a combination of individual drip pans
and diversionary structures or impervious decking and drains that route the
oil to a tank or a sump. In all these cases it is imperative that procedures
and equipment be provided for removing the collected oil on a regular basis.
Small-volume drip pans with no drain/sump are somewhat impractical if they
are exposed to rain, since they will overflow and would require almost con-
tinual inspection.
A commonly used system that has proved effective is shown in Figure B-10
and consists of curbed and impervious platform structures that collect oil
and water, and divert these fluids to drains through which they flow under
gravity to a large sump or caisson that allows collection and treatment. Oil
60
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SALT WATER
TANK PLATFORM-
HEATER-TR EATER
PLATFORM
OIL STOCK TANK
PLATFORM
SUMP
SUMP PLATFORM
SEPARATOR
PLATFORM
HEADER
CHECK VALVES ~ ~1"
•"" x
WELLHEAD
FLOWLINES
(SUBMARINE)
Figure B-9. Offshore production facility.
which is collected is either pumped back into the system or disposed of
properly.
It is imperative that the collection system be leakproof, i.e., the plat-
form must be impermeable, the drain pipes must be sound, etc.
Sump System—
The sump system should be of sufficient volume to contain any anticipated
leaks and spills. This can be based on past experience and on the history of
the facility in question.
An automatic sump pump should be used to remove any collected oil or
rainwater and a backup system should be available in the event that the pri-
mary system becomes inoperative.
In general, all sumps require regular inspection. Typically, the maximum
inspection interval should be one day.
61
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OIL
RETURNS TO SYSTEM
1
PUMP
OIL & STORM WATER
FROM DRAINS
SUMP
TO WASTEWATER
TREATMENT UNIT
;• » r~* I Ivl I ^ X
/ J ff
SUMP
SECTION A—A
TREATER
SALTWATER
TANK
a7~*\*
Qi
STOCK TANKS
O DRAIN
— DRAINLINE
•— DRAINLINE BELOW PLATFORM
^ DIRECTION OF FLOW
Figure B-10. Curbed platform drain system.
62
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Separator and Treater Dump Valves—
It is essential that when dump valves on separators and treaters are set
to close upon a failure in the system, the relief valves not be vented to the
atmosphere. The effect of venting directly into air would cause oil to spray
randomly in all directions, including into the water. It is recommended that
if the dump valves are set to close upon failure, the pressure relief valves
be vented to a surge tank or scrubber which has the structural strength and
volume to adequately handle the fluid flow and pressures.
In no event should a dump valve failure cause fluids to be discharged
through a flare line if the flare line does not extend to a disposal pit or
other containment structure.
Tanks—
All atmospheric storage or surge tanks should be equipped with high liquid
level detectors that will either activate alarms and/or control flow to the
tanks. It is essential that tanks must be in good condition and not leaking
or in imminent danger of leaking/failing.
All tanks should be adequately protected internally and externally from
corrosion, as required to prevent leakage or spillage. Methods of controlling
corrosion may include protective coatings, cathodic/anodic protection, chemi-
cal treatment of oil, etc.
Spill Prevention Equipment and Systems—
In order to maintain a relatively spill-free facility, it is vital that
proper inspection and testing procedures be prepared and implemented for pol-
lution prevention related equipment. Equipment of particular importance
includes.:
Liquid level sensors
Pressure sensors
Sump pump systems «
Valves
Alarms
Corrosion prevention equipment
Integrity of containment and diversionary structures (platform sur-
faces, drain line, sumps, disposal pits, etc.)
To ensure that the procedures are being followed, it is mandatory that
authority for carrying out the procedures be properly delegated and that the
records associated with the inspections be properly kept. It should always
be assumed that if records of inspections are not being maintained, then the
inspections are not being performed.
63
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Well Control—Systems and Equipment—
The wells should be capable of being shut in when an abnormal pressure
or fluid flow condition exists. The controls to shut in the well should be
fail-safe. Due to the nature of this surface/subsurface valving, it will not
be practical for the inspector to much more than verify that the valves are
properly connected and that the equipment is not experiencing a leak. It
would be detrimental to the operator for the inspector to insist on witnessing
a well shut-in, since restarting the well can be time-consuming and quite
expensive.
Blowout preventor valve assemblies are devices that enable the operator
to contain a well during workover or drilling operations. A diagram of a BOP
assembly is shown in Figure B-ll. It includes two annular rings (S and T)
that can seal around the drill pipe or the "kelly" (drive shaft). It also has
two ram-type valves that can seal around the drill pipe during an emergency.
i 41
• "vrx *-•— ss.lr.1. ,,
:c "' •;•:: i - i 5r: '
£
— H
" '; !•«
i. i N
C Kelly
H Rotary machine
J Rotarymachmedrive
K Vibrating mudscreen
L Outlet for drilling fluid
R Cut-out section of drilling floor
S Hydraulically operated blowout preventer
T Hydraulically operated blowout preventer (rnastergate)
U Outlets, provided wuh valves and chokes for drilling fluid
when upper blowout preventer is closed
V Surface casing (conductor)
W Cement bond between casing and borehole wall
X Drill pipe
Y Heavy, thick-walled pipe (drill collars) at bottom of drilling string
Z Roller bit (for hard formations)
A Flow of drilling fluid
Figure B-ll. Blowout preventor assembly.
64
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A BOP assembly must always be utilized during a workover or drilling
operation and must be of sufficient strength to withstand the full pressure
that can be produced in the well. (This does not include wire line workovers,
which may not require or utilize BOPs.)
Flowlines and Pipelines—
Flowlines are a frequent source of oil spill pollution. They are usually
in water and/or silt and are therefore difficult to inspect to verify their
integrity. It is usually not practical to hire divers, X-ray equipment, etc.
to inspect them on a regular basis. Therefore, the producing companies will
sometimes wait until the flowline begins to leak before corrective action is
taken. Sometimes the "corrective action" may be a clamp that seals around
the leaking area and stops the flowline from leaking for a period of time,
until a. new leak occurs.
The obvious disadvantages to this process are (1) oil pollution itself
is utilized as the method of determining a leak, and (2) the method of repair
can be classified as temporary, i.e., the flowline may be "thin" along the
entire length. (It is not uncommon to see flowlines that have clamps every
4 feet.) Therefore, a flowline that has failed may be in need of replacement,
especially if it has a record of repeated failures. Preventive maintenance
programs can be established that will, through testing and statistical analy-
sis, reduce the risk of oil spills from this source to a minimum.
To avoid flow from an active well to another flowline (which may be in-
active and/or open) it is necessary that the individual flowlines have check
valves at the header or manifold.
In the event that the well is capable of producing pressures, either
naturally or with artificial lift, which are in.excess of the safe working
pressure of the flowline, then that flowline needs to have either a pressure.
sensor that will shut in the well automatically when the safe working pressure
limit is reached, or a pressure relief system to a safe vent.
Offshore Drilling/Workover Rigs
As indicated previously, each oil drilling and workover rig should have
its own SPCC plan. Offshore drilling rigs have many SPCC requirements that
are similar to those for oil production facilities; however, there are some
differences in operation and construction that are significant to the
inspector.
The type of drilling rig is usually determined by the depth of water,
prevailing winds, and other environmental or operational conditions. For shal-
low depths encountered in inland waters of protected coastal waters, barge
rigs are normally used. For offshore waters, platform rigs are utilized.
Barge Rigs—
Drill barges are used in shallow water locations such as the canals,
bayous, and lakes in Southern Louisiana and Mississippi, etc. The barges are
towed to the location, submerged to touch bottom, and kept in place by piles
driven into the bottom. Since the setup time for drilling is usually a matter
65
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of a few hours, barge rigs are employed whenever possible. A pictorial view
of a barge rig is shown in Figure B-12. The areas of particular interest to
spill prevention are illustrated in Figure B-13.
The upper level of the rig contains the derrick, rotary table, drilling
operator s and controllers, draw-works, drill-pipe, living quarters, and cas-
ings. Occasionally, it will contain small quantities of diesel fuel, gasoline,
solvents, lubricants, etc. As a result, the upper-level areas which contain
oil materials need to be contained so that all liquids will drain in a con-
trolled manner and not flow over the side of the barge into the water. It is
common practice to weld steel plates Co the edge of the deck to limit the out-
ward flow of liquids. The inspector should verify that the curbing has the
required integrity and is free of holes, pitting, cracks, and gaps. Occasion-
ally, the crew will drill holes in the curbing to release water that may be
standing in a low area. Obviously, this negates the effectiveness of the curb
and is not allowable. If the operator determines that it is not in his best
interests to provide curbing around the deck, he may choose to install indi-
vidual collection equipment at each oil source.
The intermediate level usually provides space for the drilling fluid sys-
tem, which includes the mixing hoppers, pumps, shaker, and settling pit, and
storage for liquids and powders. "This level does not ordinarily contain any
oil products, but if it does it should be contained in a manner similar to
that described previously , to eliminate the possibility of oil discharging
into the water.
Figure B-12. Barge-mounted drilling rig.
66
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UPPER DECK CURB
FLOOR DRAIN
HULL
OF BARGE
& BALLAST TANKS
SUMP/SEPARATOR
B.O.P. ASS'Y
KEYWAY/GATE
(SEE FIG. B-14)
Figure B-13. Barge collection/drainage system.
67
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The Lower level of a barge rig is a likely place for oil spills. It is
the location of the diesel engines, gear reducers, compressors,"fuel tanks,
and lube oil storage. The picture is further complicated by these items being
located adjacent to the ballast tanks, i.e., any oil that leaks into the bal-
last tanks will eventually be pumped overboard when water is emptied from the
ballast tanks prior to moving the barge. It is essential, then', not only that
the lower platform level be contained (to prevent oil from flowing overboard),
but that the deck be sealed to keep any oil accumulations from entering the
ballast tanks. The inspector should verify that only water can enter the bal-
last tanks, and that the curbing has the integrity to prevent oil from flow-
ing over the side of the barge.
The lower level of the barge also utilizes a "keyway" (Figure B-14) that
is a catchall sump and is located in the hull of the barge at the wellhead.
During drilling, the keyway gate and spray unit are used to prevent oil and
other contaminants from dispersing into the open water. However, since the
keyway gate is not used during transit, the drains leading to the keyway must
be kept closed then.
A more acceptable solution is to have all the drains connect to interme-
diate sump tanks that have a water leg. The water leg can then empty into the
keyway, regardless of whether or not the gate is in place during transit.
During drilling/workover, it is important that the keyway gate fit tightly to
avoid seepage of fluids from the keyway. Spray systems are also recommended
to keep oil substances away from the gate. The inspector should check the
plan and the rig to verify their implementation.
As indicated previously, the drilling contractor must utilize the proper
well control equipment, including a blowout preventer. The BOP must be sized
to handle the maximum well pressures that can be generated.
Platform Rigs—
The type of platform drilling rig in use varies with the water depth,
distance from shore, and sea state. Fixed drilling platforms are used for the
shallowest and clamest conditions. Jackup rigs are used for intermediate
depths and severer states. Semisubmersible rigs are the largest in size and
find application in the deepest waters furthest from shore. Each of these is
briefly discussed below.
Fixed Drilling Platforms—These find use in depths up to 100 feet only,
and are nearly identical to production platforms. The discussion of SPCC
features of offshore production platform presented earlier in this appendix
therefore will provide suitable information.
Jackup Drilling Rigs—Jackup rigs (see Figure B-15) are frequently util-
ized where the environment can be severe and deeper waters (to 300 feet) are
encountered, e.g., off the coast of Texas, California, Louisiana, etc. As
shown in Figure B-16, the typical jackup rig uses a rack (on the leg) and pin-
ion drive system to raise and lower the rig's legs relative to the floor of
the ocean. When the legs are on the bottom, jacking crews elevate the dril-
ling floor to above the anticipated maximum wave height, e.g., 25 to 35 feet
in the Gulf of Mexico.
63
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PNEUMATIC SEAL
B.O.P.
OIL&
WATER
ELEVATION:SECT1ON A-A
Figure B-14. Keyway for drilling rig.
69
-------
Figure B-15. View of jackup drilling rig.
Figure B-16. Rack and pinion drive in jackup drilling rig.
70
-------
Spill prevention measures are similar to the barge-type rig in that they
must have
A curbed drainage system
A sump to collect all oil
A blowout preventer
A contingency plan
Since the jackup rig is above the water and does not utilize ballast
tanks, it is easier for the inspector to determine structural integrity of
curbs, presence of oil leaks and proper functioning of sump collection equip-
ment. The inspector should check very carefully to determine that all well
shut-in devices are working properly and that inspection records of these de-
vices are being meticulously maintained.
Semisubmersible Drilling Rigs—Semisubmersible drilling rigs are quite
large, expensive to build and operate, and are used in offshore drilling to
water depths up to 2000 feet. A photograph of a self-propelled Semisubmersible
rig underway is shown in Figure B-17. When the rig reaches the drilling loca-
tion, the ballast tanks are filled, thereby lowering and stabilizing the rig.
Anchored guy lines keep the rig over the hole, thus achieving horizontal con-
trol. Figure B-18 shows the submarine features of a Semisubmersible rig.
Spill prevention measures are nearly identical to those implemented on
jackup rigs and barges, except for two areas. The blowout preventer stack is
always on the ocean floor and the riser from the BOP typically includes a ten-
sioner system, pipe slip joints, pipe ball joints, etc., to facilitate move-
ment of the floating vessel relative to the BOP.
71
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Figure B-17. View of semisubmersible drilling rig.
LOAD
SEMISUBMERSIBLE RIG
A...-
~IU
-
'
3 MVJUHI1NV3 UINt
WELL
"4r SUBSEA B.O.P.
Figure B-18. Submarine features of semisubmersible rig.
72
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GENERAL
CONTAINMENT EQUIPMENT/STRUCTURE OR CONTINGENCY PUN
SPCC PREVENTION PLAN CHECKLIST
Secondary containment and/or diversionary structures are used for possible
spill sources:
Source
Type of Containment or Diversionary Structure
Select from: Dikes, berma, retaining walla, curbing, culverting, gutters,
drains, weirs, booms, other barriers, spill diversion, retention ponds and
sorbent materials.
If the containment or diversionary structures above are impracticable,
state reasons for impracticability:
and attach a strong oil spill contingency plan and written commitment of
manpower equipment and materials required to expedltlously control and re-
move any harmful quantity of oil discharged. Check if attached:
Contingency P
Discussion:
Written Commitment
APPLICABLE EPA GUIDELINES
40 CFR PART 112.7
I 1IJ.7 Cul4dinc4 lot ilia prep.rillon
•nil InptenienUllim of • Spill Pre-
vention Control and Counlenueuure
Plan.
Tttt complete tafCC Han mall
follow the aequenee outlined belov. and
Include « dUcuulon of the facility', con-
formaiice with the appropriate guideline*
Offsbore faalllUM.
Curbing, drip pani
(Ul BumM knd collection eyiterni
(d> When It U determined that the
Installation of •truoturef or equipment
lilted In 1112.7(0) to prevent dUeharged
oil from retelling the navigable water*
. I* not practlcabfe from any onahore or
offdior* facility, tne owner or operator
ihould clearly demonttraU euoh Im-
practicability and provide the follow-
big:
(DA atrong oil aplll'contingency plan
following the provUlon of 40 CPH Part
(1) A written commitment of man-
power, equipment and material* re-
quired to expedtuoualy control and re-
move any harmful quantity of oil dU-
charged.
n
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NONPRODUCTION - ONSHORE
YES
NO
40 CFR PART 112.7
A. Drainage
(l) Drains Area diked storage areas have valves.
(2) Drain valves are manual, open-and-olose design.
(3) Rain water from diked areas is inspected before drainage.
(U) Plant drainage systems are equipped with either:
a. Ponds, ifigonna or catchment basins to retain oil or
b. A diversion system at the final discharge point which
could contain an uncontrolled spill and return the
oil to the plant.
(5) Flow of drainage water between treatment units Is by
either:
a. Natural hydraulic flow or
b. Two "lift" pvDBQps (one a spare and one permanently
installed). _
Discussion:
(I) Facility drainage (on*hor0>; <«x-
cludlna production /adWIei). Drain-
age front diked storage areas should be
restrained by valves or other positive
mean* to prevent a spill or other excee-
olve leakage at oU Into the drainage sys-
tem or Inplant effluent treatment sys-
tem, except where plan systems are de-
•Igned to handle auoh leakage. Diked
area* may be emptied by pump* or elec-
tors; however. Uteae should be manually
activated and the condition of the accu-
mulation should be examined before
starting to be iure no oil will bo dis-
charged Into the water.
(ft) Mapper-type drain valve* ihould
not be used to drain diked anas. Valvee
used for the drainage of diked area*
ahould, a* far a* practical, be ot man-
ual, open-and-oloaed design. When
plant drainage drahu directly Into
water oounee and not Into waitewater
treatment plants, retained storm water
should be Inspected as provided In para-
graph UHanill) (B. O and D) baton
drainage.
(Ill) Plant .drainage systems from uoi
diked areas should. If possible, flow Into
ponds, lagoons or catchment basins, de-
signed to retain oil or return It to the
facility. Catchment f*f ***tf should not be
located In areas subject to periodic
flooding.
If plant drainage Is not en*
glneered a* above, the anal discharge of
all In-nlant ditches should be equipped
with a diversion system that ooul4. In
the event of an uncontrolled spill, return
IbeoUlo the plant.
(v) Where drainage waters are treated
hi more than one treatment unit, nat-
ural hydraulic flow should be used. If
pump transfer Is needed, two nut*
. pumps thimM be provided* ^A s>fc leasfe
• one of the pujnp^ should be, pemunenlsV
Installed when ftuch treatment Is con-
tinuous. In any event, whatever te«b>>
inl4)UM art used facility drainage ivstttm
should be adequately engmewd M pro-
vent o|| from teaching navlgablk waif re
la the mgpt ot equSpmenl fafiiire or
human «rroi at (h* (
-------
NONPRODUCTION - ONSHORE (Continued)
40 CFR PART 112.7
B. Bulk Storage Tanks
(1) Tank material and construction are compatible with fluid
stored.
(2) Secondary containment volume is greater than the largest
single tank capacity plus an allowance for rainwater.
(3) Drainage of rainwater from diked areas into open waters,
by-passing laplant treatment. Is accomplished according
to the f clewing:
a. Normally the by-pass valve is sealed closed.
b. The rainwater Is Inspected to insure compliance
with water quality standards.
c. The by-pass valve is opened and reaealed under
responsible supervision.
d. Records are kept of bypassing and drainage events.
(10 Burled metallic storage taalu:
a. New tanks are coated and wrapped to reduce corrosion.
b. Cathodlc protection is provided for tanks as
necessary.
o. Tanks are pressure tested on a scheduled, periodic
basis.
(5) Partially burled metallic tanks are avoided (for
stored oil) unless adequate shell coating is provided
for the buried portion.
YES NO
(3) Bulkttoraottanki (onsnore); (ex-
cluding production /ocUKto). (|> NO
tank should bo used for tho storage of
oil unless IU material and construction
are compatible with tho material stored-
and condition* of storage *uch aa pree-
8uro and temperature, etc.
(II) All bulk storage Unk Installations
ahould bo constructed so that a sccond-
ary mean* of containment Is provided for
the entire contents of the largest single
tank plus sufficient freeboard to allow
for precipitation. Diked area* ahould be
sufficiently Impervious to contain spilled
oil. Dikes, containment curb*, and pita
are commonly employed for thla purpose.
but they may not always be appropriate.
An alternative lystent could consist of a
complete drainage trench enclosure ar-
ranged so that a spill could terminate
and be safely confined In an In-plant
catchment basin or holding pond.
(Ill) Drainage of rainwater from the
diked area Into a storm drain or an efflu-
ent discharge that empties Into an open
water course, lake, or pond, and bypass-
ing the In-plant treatment system may
be acceptable U:
(A) The bypass valve la normally
sealed closed.
(B) Inspection of the run-off rain
water ensures compliance with appli-
cable water quality standards and will
not cause a harmful discharge at defined
In 40 Cm 110.
(C) The bypass valve Is opened, and
reseated following drainage under re-
sponsible supervision.
Adequate records are kept of
such events.
(lv> Burled metallic storage tanks rep-
resent a potential for undetected spills.
A new buried Installation should be pro-
tected from corrosion by coatlnga,
oathodlo protection or other effective
methods compatible with local soil con-
ditions. Such buried tanks should at Uasi
be subjected to regular pressure testing.
(v) Partially burled metallic tank* for
bhe storage of oil should be avoided, un-
less the buried section of the shell Is aide--
quately coated, altute partial ••burial In
damp earth can cause rapid oomilen of
mo tall to surfaces, especially at tbe eartfe/
air Interface.
-------
O>
NONPROUUCTION - ONSHORE(ConCinued)
(6) Aboveground tanks are tested by one of the
following nethoda:
a. Hydrostatic testing
b. Visual inapeotion
c. Shell thickness testing (cooparison
records of shell thickness reduction
are Baintalned)
(7) Internal heating coil leakage is controlled
by one or more of the following:
a. Monitoring the steam return or exhaust
lines for oil.
b« Passing the steam return or exhaust lines
through a settling tank, skinner or other
separation system.
c. Installing external heating systems.
(8) All bulk storage tanks are externally
inspected on a monthly basis (including
seams, rivets, bolts, gaskets, notzle
connections, valves, connected pipelines
and tank foundation and/or supports) for
leaks or failures.
(9) Tanks are fail safe engineered by one of the
following:
a. High liquid level alarms with an audible
signal at a constantly manned station.
b. High liquid level pump cutoff devices.
o. Direct comnunication between the tank
gauge? and pumping station.
d. One fast means of determining the liquid
level in tanks (such as digital ccnputers,-
telepulse or direct visual gauges).
YES
40 CFR PART 112.7
(vl> Aboveground Unks should be
subject to periodic Integrity letting, tak-
ing Into account tank design (flouting
roof. etc.) and tulng such technique* a*
hydrottatlo letting. «iiual Inspection or a
system of non-destructive shell thickness
tenting. Comparison records sttould be
kept where appropriate, and lank rap-
ports and foundations should be In-
cluded In these Inspections. In addition,
the outside of the tank should fre-
quently be observed by operating person-
nel for signs of deterioration, leaks
which might cause * spill, or accumula-
tion of oil Inside diked areas.
To control leakage through de-
fective Internal heating colU. the fol-
lowing factors should be coiuldered and
auplled. as appropriate.
(A> The steam return or exhaust lines
from Internal heating colls which dis-
charge Into an open water course should
be monitored for contamlnallc . or
passed through a settling tank, sklmmsr.
or other separation or rcteaUw system.
High liquid level alarms with an
audible or visual signal at a constantly
manned operation or survelllsruvs sta-
tion; In smaller plants an audible air
vent may suffice.
(B> Considering else and complexity
of the facility, high liquid level pump
niton devices set to stop flow at a pre-
determined tank content level.
(C» Direct audible,' or code signal com-
munication between ue tank gatlgv and
the pumping station.
A fast response system for deter-
mining the liquid level of each bulk stor-
age tank such as digital computers. Ulc-
piilse, or direct vision gauges or Uwdr
equivalent.
(K> Uquld level sensing devices should
be regularly tested to Insure proper
operation.
(U) Plant effluent* which are dis-
charged Into navigable waters should
have disposal faculties observed fre-
quently enough to detect possible system
upsets that could cause an oil spill event.
Visible oil leaks which result In a
loss of oil from tank seams. gsskeU. rivet*
and bolU sufficiently large to eause Out
accumulation of oil In diked area* should
be promptly corrected.
afoblle or portable oil storage
tanks (onshore! should be positioned or
located so as to prevent ipulsd oil from
reaching navigable waters. A secondary
means of containment, such as dikes or
catchment l&slns, should b* lujnlstvMl
for the largest single coinpartrnent or
tank. These facilities should b* locate*
where they will not be subjeqt <
Hooding or
-------
NONPRODUCTION - ONSHORE (Continued)
a. Liquid level sensing devices are
Inspected and tested on a scheduled,
periodic basis.
(10) Frequent plant effluent observations to
detect upsets are made*
(11) Mobile storage tanks are properly
positioned to prevent spill reaching
navigable water.
Discussion:
YES NO
40 CFR PART 112.7
(3) facility trantler operation*. pump-
Ing, and in-plant proccit (onihore); (ex-
cluding production tacUtttct). liurled
piping Installations ihould have a pro-
tective wrapping and coaUng and should
be catltodlcally protected If aoll condi-
tions warrant. If a secUon of buried Una
la exposed /or any reason. It should be
carefully examined for deterioration. If
corrosion damage la found, additional
examination and corrective action should
be taken as Indicated by the magnitude
of the damage. Ah alternative would be
the more frequent use of exposed pipe
corridors or galleries.
Intra-Facility Transfer Operations, Pumping
and Inplant Process
A. Burled Pipelines
(l) Pipelines are wrapped and coated
to reduce corrosion.
(2) Cathodlo protection is provided for
pipelines aa needed*
(3) When a pipeline section is exposed, it
is inspected and corrective action taken
as necessary.
-------
NONPRODUCTION - ONSHORE (Continued)
YES
NO
40 CFR PART 112.7
Pipeline terminal connections are capped or blank-
flanged and narked if the pipeline !• not in ser-
vice car on standby service for long periods*
Discussion:
C. Pipe supports are designed to minimize abrasion
and corrosion and allow for expansion and contractions4
Discussion:
00
Q. All aboveground valves and pipelines are inspected
on a scheduled, periodic basis (including flange
Joints, valve glands and bodies, catch pans, pipe-
line supports, looking of valves, and metal surfaces.)
Discussion:
(lit When a pipeline la not in service.
or In standby service (or «n extended
time the terminal connection at the
transfer point should be capped or
blank-flanged, and marked at to origin.
Pipe support* should be properly
designed to mlnlmlM abrasion and cor-
rosion and allow for expansion and con-
traction.
Uv) All aboveground valvw and pipe-
lines should be subjected to regular ex-
amination* by operating personnel at
which time the general condition of
Items, such a* flange joint*, expansion
JolnU. valve glands and bodies, catch
pan*, pipeline supports, loosing of valve*.
and metal aurf aeei should be assessed. In
addition, portodto pctuure testing may
be warranted (or piping la area* where
(acUlty drainage Is such that a faOiue
night lead to a spUl event.
(v) Vehicular traffic granted entry Into
the facility should be wanted verbally
or by appropriate sign* to be Mire that
the vehicle, because of It* alat. will not
E. Vehicles entering the facility are inspected and/or
warned to avoid damaging aboveground piping.
Discussion:
-------
NONPRODUCTION - ONSHORE (Concluded)
40 CFR PART 112.7
Discussion (oont'd)
D. Intro-Facility Tank Car & Tank Truck Loading/Unloading
Tn requirements
A. Loading/unloading procedures meet the
and regulations of the Department of Transportation.
B. The unloading area ha* quick drainage system*
C. The containment system will hold maximum capacity of
any single tank truck loaded/unloaded in the plant.
D. An interlocked warning light or physical barrier system
or warning signs are provided In the loading/unloading
areas to prevent vehicular departure before disconnect
of transfer lines*
E. Drains and outlets on tank trucks and tank cars are
checked for leakage before 1f""M"g or
Discussion:
<4> -facility tank car and lanfc (ruck
loading/unloading rack (oiuhorc). (It
Tank CM and Unk truck loadlng/un-
YES NO loading procedure! ahould meet Ut« mln-
—— —— imiunreQUlremenU and regulation eetab-
Uehed by the Department ol Transpor-
tation.
-------
OIL PRODUCTION - ONSHORE
40 CFR PART 112.7
oo
O
E. Oil Production - Onshore ,
(1) Secondary containment drains are
closed and locked.
(2) Ditches, sumps, traps, etc. are
kept olean ot oil
(3) Tanks are compatible with oil stored.
(It) Tanks fc treating equipment have second-
ary flOtlta^yVf^P1^ •
(5) Tank batteries are failsafe.
(») Tanks have extra capacity.
(b) Equalising lines are used.
(o) Vacuum eliminators are used.
(d) High level alarms are used.
(6) Piplng/pluntoing egulpnent is Inspected
regularly.
(7) Disposal pits are kept at sufficiently
low levels.
(8) Flowline preventive maintenance program
is utilised.
Discussion:
YES NO at GU production faclllMe«(on*nore>.
(I) Definition. An onthore production fa-
cility may Include.all wells, flowllnet.
separation equipment, ttoraga faclUUet.
gathering llnet, and auxiliary non-trent-
portatlon-relaUd equipment and faclll-
tle* In a tingle geographical'oil or gaa
field operated by a'tingle operator.
OU production laeUUu (ontftort)
drainage. (A) At tank batteries and cen-
tral treating station* where an acci-
dental discharge of oil would have a
reasonable pottlblllty of reaching navi-
gable water*, the dike* or equivalent re-
quired under 1111.7(0 (O thould have
drain* closed and tealed at all lime*
except when rainwater It being drained.
Prior to drainage. Uie diked area thould
be Inspected at provided In paragraph
(eXaUIID (B). Ot, and (Dt. Accumu-
lated oil on the rainwater ihould be
picked up and returned to ttorage or dlt-
poted of In accordance with approved
method*.
(B> Field drainage dllchei. road
dltche*. and oil trap*, tumpa or tklm-
mert. If tucli exltt. ihould be Impeded
at regularly acheduled Interval* for ac-
cumulation of oil that may have escaped
from tmajl leaks. Any tuch accumula-
tion* thould be removed.
(im OU production facility (oiwhore)
bulk *lora0« tanJkt. (A> No tank thould
be iiied for Uie ttorage of oil unlett IU
material and construction an compati-
ble with the material itored and the
condition* of ttorage.
All lank battery and central treat-
Ing plant Installation! ihould be provided
with a taoondary mean* of containment
for the entire content* of the largett tin-
gle tank If feasible, or alternate system*
tuch at those outlined In I ua.7(cl(l>.
Drainage from undlked area* should bo
safely confined In a catchment basin or
holding pond.
(O AU tank* containing oU tbould bo
vltually examined by a competent per-
eon for condition and need for mainte-
nance) on a eoheduled periodic bail*.
Buch examination thould Include the
foundation and rapport* of tank* Uxat
are above the surface of the ground.
Haw and old tank battery Initalla-
Uon* ihould. at far a* practical, be fall-
tale engineered or updated Into a tall-
Mfe •neutered IntUllatlon to prevent
iplUe. Oantlderatlon thould b* given to
on* or more of the following:
(II Adequate tank capacity to attur*
that a tank will not overfill ihould a
pumpar/caugM be dtUyed lu uakiog hU
regular round*.
(1) Overflow equallalng line* between
tank* aa.Uui a full lank can overlbnt to
an adlacent Unk.
(Jt Adequate vacuum protection to
prevent tank collapee during a plpelin*
run.
(41 High level teuton to general* and
tranwntt an alarm tignal U the computer
where facUltla* are a part of a computer
production control tytUm.
(lv> fooUUy traniltr operalloiM. oil
produeildtt /acUlly (onihort). (A) AU
above grotmd valvet and pipeline* ihould
be examined periodically on a aoheduled
batU Mr'generai condition of item* tucfa
a* QaogtloiuU. valve glandt and bodice,
drip .pant, pipeline tupporU. pumping
well potlih rod atuffliM boiet. bleeder and
gauge valve*.
(B> Salt water (oil field urine) dlt-
poial faolUtle* should be examined often.
particularly following a tudden ehange In
atmotpherlc temperature to dttcct pot-
tlbl* *ytUm upeet* that could, oautt an
oil dlacharge.
(C) Production facUltle* thould have
a program of Bowline maintenance to
prevent tpillt from thle tource. The pro-
gram tliould btcluda periodic examlna-
Uont, corrotlon protection, flowllna re-
placement, and adequate record*, a* ap-
propriate, for the Individual facility.
-------
DRILLING AND WORKOVER - ONSHORE
40 CFR PART 112.7
F. Oil Drilling and Workover (Onshore)
(1) Secondary containment is provided.
(2) Blowout preventers are utilized.
Discussion:
YES NO
«u» uu uniting ana workover /oeMMfn
(onsfcore) (It Mobile drilling or woriraiver'
equipment should be positioned OF lo-
cated w> M to prevent spilled otf from
reaching navtg«bld waUn.
(II) Depending on the location, catch-
ment baalni or dlvaratan iinwturea may
b«i necMaaiy to Intercept and contain
ipUU of fuel, thide oil. or oily drilling
fluids.
(Ill) Before drilling below any casing
tiring or during workover operation*, a
blowout prevention (BOP) auembly and
well control lyotem ahould be Installed
Uiat U capable of controlling any well
head prewure that U expected to be
encountered while that BOP aaaombly U
on the well. Owing and BOP Installation*
ahould be In accordance with State reg-
ulatory agency requirements.
-------
OIL DR1I.LINC/WORKOVER ANu PRODUCTION - OFFSHORE
OO
0. Oil prllling/^orkover and Production -
Offahore
(1) Drainage/collection equipment 1*
properly installed?
(2) Sump* are properly "lied, and have
a preventive giainte&ance prograa,
and are kept free of ollt
(3) Bump pump/control* are redundant
(when automatic)T
(k) It dump valvea are eet to be oloaed
in the event of failure, are Mas-urea
taken to prevent oil discharge* to
vatert
(9) Are bleb level alarm* utilised on
atorage and pressure tankeT
(6) Tanka are protected frou corroalont
(7) Inspection and testing procedure! are
are written and lapleaentedt
Dlacuacion:
YES
HO
40 CFK PART 112.7
(II Ott 4rW*t. prodiulkm. or work-
ainrlacUUItt lofikorck. (It Definition:
•An oil drilling, production of workover
f acllllr (ooVdtoret* ma* Include all drlll-
tiil at workovor equipment, well*. Bow-
line*, gallieruig line*. plaUorm*, Mid
auillurj nontranaporlaUon - related
equipment and lacllllle* In a tlmle geo-
(niihlwl oil or IM Oelil oponttcd 6» t
iliulo otKimlor.
till OU draliuie collullun cqulpnienl
•iHHild be uud to prevent »nd conltol
(null oil iiilllaf • cround puinix. (luidi,
Vftlvea. AMile*. BK|uin>lon lolitU. tioiei.
drain Unci.»«c|i»r«ior». treiler*. Unit.
and allied equipment. Drain* on Uia
f aclilly ahoiild !>• controlled and directed
toward a central collection aump or
equivalent collection oriUiu mfflctent to
prevent dUcliariee of oil Into Uu natlga-
bla watera al tha Onlted Bute*. Wh»r«
dralni and aumiic ara not pracUcabl*
oil conlalned In collection equipment
auould In removed M alien M oeccAiarr
• to prevent ovcrAow.
IIU) Pbr laellUlei employlni a tump
•y«ten>. nuitp and dialiu aliouM bo ade-
. quatelr elted and a iiiar* pump or equiv-
alent method ahoutd be available lo
tenant liquid Irom the etunp and awure
•that oil doee not euapa. A rc|Ul«r evhed-
»Kd MvvfiiUva maintenance liupecllon
and teethif pragran aliould be emulated
lo awura nllable operation of the liquid
removal eiretam and pump aUrt-up da-
vice. Bedundant autamatlo eump puinpe
and control device* ma> be required on
eome buUllatlaiu.
Prewure tank* ilmuld be equipped
•llh high and low preaiur* Miulug de-
vice* lo activate ail alarm and/or con-
trol the How or other acceptable alterna-
tive* lo prevent oil dlacharge*.
(till Tank* ihoiilil be equipped with
eullable corroilon protection.
Ivllll A written procedure lor liupect-
Ing and leillnf pollution iwevenllou
equliuntnt and
-------
OIL DRILLING/WOUKOVER AND PRODUCTION - OFFSHORE(Continued)
40 CRF PART 112.7
YES
HO
CD
OJ
(6) Testing/Inspection occurs on regularly
scheduled baalat
(9) 8urfaoe/aubaurface abut-In valvea are
properly activated by pressure or
flow, eto.t
(10) B.O.P.'a aro utilised during drilling/
vorkovert
(11) Well surface ehut-ln valvea have re-
dundant or final-close valvlngt
Instructions have been prepared for
contraotora and auboontractora ao that
the work la performed In a cafe and
pollution free mannert
(13) Manifolds have checkvalvea. Installed on
Individual flowllneaT
(lU) Where well pressure can be greater than
the saf e working pressure of the flow
lines - are veils automatically abut-In
when the pressure exceeds the safe UnltT
(15) Are all pipelines protected by corrosion
prevention systems?
mi Testing and inspection of Uu pol-
lution prevention equipment and systems
at the laclllty should be conducted by Utt
owner or operator on a scheduled peri-
odic bail* commensurate with tbe com-
plexity, condltloni and clrcunulancoi of
the facility or other appropriate regula-
aurface and lubturfac* well shut-
In valvei and device* In use at the facil-
ity eliould be sufficiently described to
determine method of activation or con-
trol, e.g.. pressure differential, change In
fluid or flow condition!, combination at
pressure and flow, manual or remote con-
trol mechanUnu. Detailed record* for
each well, while not necessarily part of
the plan ihould be kept by the owntr or
operator.
(ill) Before drilling below any cailng
airing, and during workover operation!
a blowout preventer (BOPk assembly and
well control system ehould be Initalled
that U capable of controlling any well-
head preuure that U expected to be en-
countered while that BOP auembly U
on the well. Gating and BOP installation*
ehould be In accordance with BUle reg-
ulatory agency requirement*.
<«U> Extraordinary well control meai-
ure* ehould be provided ihould emer-
gency condition*. Including Or*', loe* of
control and other abnormal condition*.
occur. Hie degree of control tyttem re-
dundancy should vary with haunt ex-
posure and probable consequence*' of
failure. It U recommended that aurtac*
•hut-In *y«tem* have redundant or "fall
clo«e" valvlng. Bubiurface safety valve*
may not be needed hi producing well*
that will not flow but ehould be Installed
a* required by applicable BtaU regula-
tion*.
(xil!> In order that there will be no
mleundentandlng of Joint and separate
dutle* and obligation* to perform work.
In a safe and pollution free manner.
written Instruction* should be prepared
by the owner or operator for contractor*
and subcontractor* to follow whenever
contract activities Include servicing a
well or systems appurtenant to a weU or
pressure veaacl. Buch Instruction* and
procedure* ihould be maintained at the
offshore production facility. Under cer-
tain circumstance* and conditions such
contractor activities may require the
presence at the facility of an authorised
representative of the owner or operator
who would Intervene when necessary to
prevent a spill event.
Ulvk Air manifolds (headers) should
be equipped with check valves on Indi-
vidual flowllue*.
Uvt It the shut-in well pressure I*
greater than the working pressure of the
Bowline and manifold valve* up to and
Including the header valve* modeled
with that Individual Oowlloe. the flow-
line should be equipped with a high pre*-
•suro sensing device and shuUn valv* at
the wellhead unless provided with a pres-
sure relief system to prevent over pres-
suring.
a
faculty should be protected from corro-
sion. Method* used, such a* protective
coaling* or cathodlo protection, should
be discussed.
-------
OIL DRILLING/WORKOVER AND PRODUCTION - OFFSHORE (Concluded)
40 CFR PART 112.7
YES
NO
(16) Are submarine pipelines protected from stresses
(waves, fishing lines, etc.)?
(17) Are submarine pipelines in good operating condi-
tion and Inspected on a periodic basis for
failures (if it is impractical to visually
Inspect - do they have a statistical prevention
program?)
(xvll) Bub-mnrlne pipelines ttppinten-
ant to the facility should be adequately
protected against environmental stresses
and other activities such as Ashing
operations.
(nv'.'M. Sub-marine pipelines appurten-
ant to the (acllkty should be In good
operating condition at «X\ times ana m-
epected on a scheduled periodic basis for
failures. Buch Inspections should be
documented and maintained at the
facility.
Discussion:
00
-------
FACILITY OPERATION
AO CFH PAHT 112.7
Inspections and Records
A. Hie required inspections follow written procedures.
B. The written procedures and a record of inspections,
signed by the appropriate supervisor, are included
in the 8POO -'—
Discussion!
YES
NO
oo
Cn
flecurity
A. Plant* handling or (taring oil are fenced.
B.
C.
Entrance gatea are locked and/or guarded when
the plant ia unattended or not in production.
Any valvea which pernlt direct outward flow of
a tank's contents are locked closed when in non-
operating or non-standby status.
D. Starter controls on all oil pumps in non-operating
or non-standby status are locked or electrically '
isolated in the "off position.
E.
H»o loading/unloading connections of oil pipe-
lines are capped or blank-flanged when not in
service or on standby service for extended
periods.
<•> iMpulloat *«d record*. Inapee-
Uon* required bjr Ibla part ehould U In
accordance with arrUUn procedural do-
Teloped fur the facility b» the owntr or
operttar. lluw wrlltao piocMturu uid
• record of lit* liupcoUoiu. ilfned bf UM
. tpproprul* nitxrTbor or lotpeclor.
diould be niMl* p«rt of uu BPCO Plan
•nd mtluUlued for * ptrlod of litre*
(I) Security leicludtii tU ftaiuoHatt
/oclllllMt. U> All plwU handUof. proc-
tMlnf. uid itoriui oil ihould b* fidlr
fenced, luid'enlnnct (tie* (liould b*
locked and/or fiurded when the plaol
U not la production or b unalUndtd.
Ill) Tlw muter flow and drain val»c*
and any olhar «al«e* that wtll permit
dlioct outwud flow of UM taukl con-
Uiit to Ibe turfaoa ahould ba tocuraly
lacked la lit* cloedU pMllloa wlien In
naa-o|i*raUii« or non-ilandbr lUtuei
flllk lit* (tarter control on all oil
pump* aluiuM U locked In the -oO"
potJUoa or located at a til* aeceulbl*
only to aulhorUtd penonnal •ben u>*
punipe u«, la * oan-opeiaUn( or con-
tlandbr ilalu*.
Ill) Tlw loedlni/unloadlDf connec-
tloni of oil pipeline* aluuld b* aecunlf
capped or blank-Hauled •ban nut to
aenlce or elaoiiby eervk* for an at-
tended lUue. TliU eecurtiir praoUce
ahould alao apply to ptptllnM that ar*
emptied of liquid tonltal either b»
dralnlni or b» Inert |U pmeura.
-------
FACILITY OPERATION (Concluded)
F. Deacription of the lighting around the facility:
Discussions
oo
ox
Personnel; Training and Spill Prevention Procedure!
A. Personnel are properly Instructed In the followIngi
(1) Operation and maintenance of equipment to pre-
vent oil discharge*, and
(2) Applicable pollution control law*, rule* and
regulations.
B. Spill prevention briefings for the operating per-
sonnel are conducted on a scheduled, periodic basis.
YJa no
40 CFK I'AHT 112.7
lit Facum lignum niouM U con-
meiwirUa »IU> Uw trp* tod location ol
th* IftcUHy. CMukUrellaa *lioulfl b*
•ticn tar I/O Hteovery ol *plll* oo-
currinf during boon ol dufciuu. both
bjr opeitgnc berunoel. U pnunl, anil
bl nau-oMUUn|r ptrwuuol lUw tta-
cnl putolta, ti>al italic*. *lo.t uxl (B>
pnnntlao at wU)> .occurring Uuauib
•cb al fr-vUllH,!,
oai ffwmut Katoin« and ,t*u
pr«iKp|(w mtytttVM, «J> Owiitu or op-
onion *M rMpomlbta i« prapcriy ta-
otrucUui Ui*H IM»UUI«| la lit* opwtUoa
uiii uikluUtu-uc* ol wjulpmwil la pn-
vcnt Ih* dUeliuiM ol all M>4iin>Uc*J>U
polluUaa«Bnln>l Uwi. rolM M4.r*fUlit-
HOIU.
(Ilk Each »pBllc*l>l* tKlllIf ihoulil
lutv* k dml«D4Ud twnoa who U Koaunt-
kUo lor all «i>UI pmakUNl *nd «*>o ro-
parU to Un* muugmuDt. .
(III! Ownon or oiMnlan (Itould
•cliedul* i *ad •aoodi^fl o41l nmtntlaa
brioflnto 4*1 Ihclr. aptnUdf p*nonn«l
•t InUrvtlt Irtqixut'Iaouih la uur*
»doQu*t*.tv>ilniUn4b>s'ol Ik* OKM.
Hui iJi-.ltalt IwDII*. «**; brt«ftni*
Fully describe methods and schedules for above:
-------
APPENDIX D
REPORT OF SPCC INSPECTION
This appendix contains all the SPCC Inspection and Documentation Report
Forms to be filled out by SPCC Inspectors:
A. SPCC Inspection Field Sheet (two sides) - EPA Form 7500-53
B. SPCC Inspection Summary Sheet (one side) - EPA Form 7500-52
C. Detailed SPCC Documentation (eight sides) - EPA Form 7500-54
Instructions for A. are on its side two, while instructions for C. are
on its side eight. These report forms are available at the EPA Regions.
87
-------
A. SPCC INSPECTION FIELD SHEET
( To be completed if SPCC Regulation is applicable to Facility • see 4QCFR Part 112.1.)
I*. NAME OF FACILITY
1C. FACILITY LOCATION
20. NAME Of OWNER AND/OR
OPERATOR RESPON9I8II.E FOR FACIUITY
ZC. MAIUINC ADDRESS
SEE
INSTRUCTIONS
ON REVERSE
IB. TYPE OF FACIUITY
26, TELEPHONE NUMBER
Anta Cod*
( )
3. TYPES Of Oik. STORED AND CAPACITY Of ABOVEaROUND AND BURIED STORAGE.
4. IS A CERTIFIED SPCC PI. AN
». NAME ANO REGISTRATION
AVAICABkE FOR INSPVCTIONt Qycs QNO
NUMBER OF CERTIFYINS ENGINEER Q NOT AWAIUABCE
9. DATE OF INSPCCTION
7. OATS Sr»CC PUAN WAS
cxRTinso QMOT AVAIUABU.C
«. IS SPCC PLAN FULLY IMPUEMSNTEOT (An til* ttcmt caited (or In eh* Plan in t/ic inttrcit oftpM pnvtntlon actually InttalltA • if obtervablef)
QNOT APPI.ICA>I.E
DOWNSTREAM (If known)
1 0. COMMENTS llncludf comment* fry owner/operator • writ* on tee* or attack txtra thtttt if n**d»d)
i ta. SPCC NO.
1 Ib. CASE NO. 11C.NPO
128. INSPECTOR (Ugn>
t3 rtO. |_Jf^oT AVAIUABUa
1 2O. DATE
1ZC. INSPECTOR (pnnti
EPA Form 7500-53 (9-80)
89
-------
INSTRUCTIONS
1. Tracts name of facility and its precise location, using geographical latitude and longitude if necessary.
2. If owner and operator are different persons, give information for both. State relation between them • is operator assignee, leases, or
employee? Who is responsible for SPCC?
3. Note capacity and whether tanks are full or not. Note tanks which store alternate oils. Check lube storage • whether buried or above-
ground (latter mora likely).
4. Note adequacy of Plan; if inadequate, state specific defects. Use 10. below for details.
5. Actual date of visit to facility.
S. Include state in which engineer is registered. If Plan was amended and the amended Plan certified by a different engineer, list information
for all engineers.
7. List for original Plan and any amended Plans.
3. Summary of deficiencies in Plan implementation. Discuss this with operator and record his opinions and comments in 10. below.
9. Specify distance and direction to nearest named stream, river, lake, bayou, estuary, etc. which will receive runoff from the facility. If
facility runoff goes to storm drain, ultimate receiving water should be named.
10. Space for comments by inspector and operator. Inspector should briefly list SPCC equipment actually in use at time of inspection, if
facility was not in compliance, inspector should include expected dates of Plan preparation and/or implementation.
11. SPCC No. refers to national EPA Data Bank. Case No. refers to Regional EPA designation.
12. Date on which Field Sheet was actually completed.
to. COMMKNTS (connnutct from other tide)
EPA Form 7500-53 (9-80) REVERSE
90
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B. SPCC INSPECTION SUMMARY SHEET
I SPCC NO.
CASE NO.
DATS Or IN3PCCTlQr>
lAME OP INSPECTOR (Signature)
DATE OP OOCUMBNTATION REPO-RT
NAME OP INSPECTOR (Print)
NPOBS NO.
1. FACILITY
a. COMPANY
ADDRESS
TELEPHONE
ZIP CODE
PACIUITY NAMS
b. PAC1UITY LOCATION
PARENT CORPORATION
AOORE9S
ZIP CODE
C. WATER 800V PROTECTED
2. PURPOSE
INITIATION: j_|Routine Surveillance ' QCoast Guard Information
Qj Spill Report Q Citizen Information i~1 Other Itoecifvl:
J Plan Preparation
1 Follow-up
Plan Implementation
Plan Amendment
3. INFECTION
INDIVIDUAL. CONTACTED
INDIVIDUAL. CONTACTED
TITLE
NOTIPICATION
4. FINDINGS
3, ATTACHMENTS (None required if facility in apparent compliance!
SOURCE IN APPARENT COMPLIANCE WITH SPCC REQUIREMENTS:
Qj Have adequate plan
Qj Not subject to regulations
Q Insufficient storage
Q No reasonadla spill expectation
PjPlan fully implemented
Q New facility operational less than 6 months
DNO
Q No plan
Q Plan not properly certified
[j Plan does not have management approval
not maintained at facility manned 8 hrs/day
Inadequate plan (detai/9d SPCC ftan review artxhed)
not fully implemented
FlPlan not reviewed within 3 years
•Detailed Observations
•Photographs
Slides
Map
•Field Drawing
•Comments
Telephone Conversations
•SPCC Plan
NONE ATTACHED ALREADY ON PILE
D G a
a a a
a a a
a a a
a a a
a a a
no D
a a a
•(ALL REQUIRED IF FACILITY IS NOT IN APPARENT COM-
PLIANCE. If photos not permitted, check "None" and explain. Add
"SPCC Plan " to List of Attachments when appropriate.!
l_| Other
EPA Form 7500-52 (6-80)
91
-------
C. DETAILED SPCC DOCUMENTATION
SEE
INSTRUCTIONS
ON PACE a
FACILITY
OAT* Or INSPECTION
1. FACILITY DESCRIPTION
I a. TYPE OP BUSINESS/OPERATION
1C. FACILITY OIU STORAGE
1C. PRCVKNTION MEASURES PROVIDED
Id. APPEARANCE Of FACILITY
t«. PAST SPIUU HISTORY
EPA Form 7500-54 (9-801
PAGE I OP a
92
-------
2. RECEIVING WATER (should a spill occur)
Za. NAME AND/OR DESCRIPTION
Q Perennial CD' ntermirtent
Q Water present at time of inspection
Q Inspector traced discharge to receiving water
Q Inspector traced apparent drainage path to receiving water
I"") Receiving water identified by company representative
l~|Receiving water identified from topo maps
eceiving water identified by other means Ispocifyl:
zt>. PHOOABUS ruow PATH TO RECEIVING WATER
1C. CUIMATIC INFORMATION PROM OWNER/OPERATOR
EPA Form 7500-54 (9-801 PAGE 2 OF s
93
-------
3. COMMENTS
EPA Form 5700-54 (9-80)
94
-------
4. SPCCPLAN REVIEW
EPA Form 7500-54 (9-80) PASS 4 Of a
95
-------
5. SPCC AMENDMENT RECOMMENDATIONS (Amendment Insoectiont only I
EPA Form 7500-54 (9-80) PACE son
96
-------
6. FIELD DRAWINGS (Attach more sheen if needed, and show north arrow or other orientation)
FACILITY
INSPECTION OATS
INSPECTOR
EPA Form 7500-54 (9-80)
PAGE 6 OF t
97
-------
7. PHOTOGRAPHS (Attach more sheets if needed 1
SUBJECT
PHOTOGRAPHER
WITNESSES
O ATE/TIM ^DIRECTION
SUBJECT
PHOTOGRAPHER
PACIUITY
WITNESSES
WITNESSES
CAMSR A/ PI UJV1/ ATTACHMENTS
FACILITY
WITNgSSSS
WITNESSES WITNESSES
DATE/TIMB/OIRECT1ON
CAMERA/FILM/ ATTACHMENTS
ATTACH PHOTOGRAPHS HERE
EPA Form 7500-54 (9-801
98
PA«« 7 OF I
-------
INSTRUCTIONS
Page 1: FACILITY DESCRIPTION
(a) Make detailed in narrative style: use extra sheets it needed.
(b) Include all storage; indicate capacity and actual amount and type of oil in each tank, including tanks not in use • above-
ground or buried. Indicate percent of oil in mixed storage and annual throughput where possible. If this information is
included on attached drawing or lists, state this here.
(c) Describe all types and adequacy of prevention measures • dikes, catchment areas, drainage systems, separators, tank
level alarm systems, drainage pumps, etc. Describe major security measures taken - locks, guards, fencing, etc.
(d) Describe maintenance at facility. Use such terms as "neat and well-maintained", "messy and poorly maintained" etc.
Describe any unsatisfactory maintenance such as oil pools, broken dikes, etc.
(el Obtain statement about past spills at this facility; observe drain controls: look for evidence of past spills.
Page 2: RECEIVING WATER
(a) This should be a recognizable river, stream, lake, estuary, etc. which can be expected to contain water at least part
of the year.
(b) Explicitly describe, using approx. distances in meters or kilometers (feet or milei). all of the drainage paths from facility
to receiving water or storm drain in (a).
(c) Add here any statements obtained about annual rainfall, runoff, flooding, etc.
Page 3: COMMENTS
Describe soil conditions as they relate to spill runoff and whether spills have a reasonable chance of reaching drainage
channels, storm drains or waterways. Obtain statements from owner/operator which indicate whether the person is aware
of 40CFR 112.
Paga 4: SPCC PLAN REVIEW
State whether facility has an SPCC Plan and whether it is adequate. Describe in detail any inadequacies in SPCC Plan or
its implementation. Include references to pertinent paragraphs of Spill Prevention Regulations.
Page 5: SPCC AMENDMENT R ECOMMENOATIONS I Amendment Inspection only)
Describe areas of past and potential oil spills and corrective actions, preventive measures and countermeasures carried out
in facility. Based on your inspection, will these features of the post-spill SPCC Plan adequately minimize the possibility
of recurrence? Why? if not, state recommendations for SPCC Plan amendments in detail - attach quantitative information,
drawings, etc.
Page 6: FIELD DRAWINGS (attach more sheets if needed and snow north arrow or other orientation}
Show: all major features with spill potential requiring spill prevention measures; all drainage features that relate to
potential spills, such as catch basins, storm drains, channels, ponding areas, dikes, sumps, etc.; the appropriate
distances in meters or kilometers (feet or miles! along drainage paths from spill potential areas to water course
or water body in 2(a).
Page 7: PHOTOGRAPHS (attach more sheets if needed!
Show inadequate SPCC features, spills, poor maintenance, proximity to waterways, and so forth. Mount photographs on
page 7; attach more sheets if needed.
EPA Form 7500-54 (9-80)
99
• Of a
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APPENDIX E. EPA-SPCC DATA BANK FOEMS
HIT' ;*
U.S. ENVIRONMENTAL PHQTSCTICN AGSNO'
OIL AMD SPECIAL MATERIALS CONTROL DIVISION
FACILITY IDENTIFICATION
(Form A)
NOTE
Alt non»chaded
areas must cantata
an entry.
0. FOR CONTROL USE ONLY
This form is to be completed in conjunction with other Oil and Special Materials Cantroi Division forms or singly where no SPCC
number has been assigned or an SPCC number is unknown. Eater the Locator Code. It consists of the first five alphabetic charac-
ters of the Facility Name, followed by the Zip Code for the Facility Site (lor of/shore lacilitiea the Zip Code portion should ba
zero lilted.).
1«- LOCATOR CODE ANO LOCATOR ZIP
(ZIP cooei
b. START-UP OATS
7 /
Enter this date
if it is later
than 01/10/74
3A-V
C.MAS THE NAME OP THE FACILITY CHANGED
WITHI_M_ THE LAST YEAR (Yft. or No) _
• . MAS TM« LOCATION Of TMC FACILITY CH AMOCO WITHIN LAST V KANT (T»« OT Ha)
2. TMK FOLLOWING INFORMATION IS RELATED TO THE FACILITY;
b. TY»C IS A»jr PABT 0» THC FACILITY
NON'TflANSPONTAriON RKLATCO*
(T«« or Hot
e. STATC
COUNTY
•. CITY
LOCATION
f. LATITUOC ». LONCITUOC
h. SUBVCY OC1CRIPTION
w
U TOTAL JTO»AO« CAPACITY O»
» ACILITYfln t*llen*>
fi
ace MI
SBC
MIN SKC
L3
3. THE FOLLOWING INFORMATION IS RELATED TO THE OWNER/OPERATOR
«. NAM8
AOOnci* C$tr««()
c. CITY
d. STATC •. ZIP
r. TSLXPMONC
4. THE FOLLOWING ARE DIRECTIONS TO FACILITY SITE (Option*! — IS "artU or !•••)
SPA f*tm 7SOW3
PNCVIOUS COITION MAY sc usca
101
-------
U.S. SNVIRCNMENTAL PROTECTION AGENCY
OIL ANO SPECIAL MATERIALS CONTROL DIVISION
INSPECTION/ENFORCEMENT REPORT
(Form E)
RIN 75JO-I5I
a FOR CONTROL USE ONLY
I. SPCC NUMBER
U the SPCC number a not entered,
complete the Facility Identification
Form.
2. DATE OP INSPECTION
MO
A A
DAY
YH
3. HAS AN INSPECTION/ENFORCEMENT REPORT BEEN PREVIOUSLY COMPLETED FOR THE DATE OP INSPECTION (aoovcl?
D YES O NO (if answer is "Yes" - complete No. 5, if applicable, then skip to No. 12.)
COMPLETE ALL APPLICABLE SECTIONS BELOW
4. *. INSPECTOR'S LAST NAME
B. INSPECTOR'S ORGANIZATION
S. SPILL I.O. (if inspection result ofspui)
ft. ESTIMATED NUMBER MAN-HOURS INVOLVED IN INSPECTION
(whole hounf
7. IS PAC1UTY SUBJECT TO PART 1127
DYES Q NO (If answer is "No" - complete No. 3 then stop)
COMPLETE ALL APPLICABLE SECTIONS 3ELOW
3. PURPOSE OP INSPECTION
A O PLAN PREPARATION ONLY
3 D PLAN PREPARATION ANO IMPLEMENTATION
9.
A Q PREVIOUS VIOLATION CORRECTED
(If 9A or B is checked - STOP HERE.)
B O.NO VIOLATION POUNO
10. VIOLATION coOE/R6FERRAUf7//0isc/iec*ed - 11. is required.)
Violation Code (check as many as three):
Z tt Failure to prepare any SPCC Plan
A U Failure to prepare an SPCC Plan in accordance with 112.7
3 O Failure to have SPCC Plan certified as required by 112.3(d)
C /~7 Failure to implement SPCC Plan
0 £17 Failure to submit information after triggering spill as required by 112.4(a)
5 £17 Failure to amend plan as required by 112.4(d)
F ry Failure to implement amendment as required by 112.4(e)
G /~7 Failure to amend, certify or implement after facility change as required by
112.5(a)
H /"7 Failure to review, amend, certify or implement as required by 112.5(b)
I. SEPERREO TO ENFORCEMENT/0
-------
ENFORCEMENT INFORMATION (Complete any/all sections below if possible)
12. DATE NOV ISSUED (by enforcement)
I/I I I/I
MO DAY YH
PINE PHOPOSSO (by enforcement)
(whole dollars)
14. DATE PHE-HEAHING CONFERENCE H6LO
19. OATS HEARING HELD
\A\\A
VTYTA
MO DAY YH
MO DAY YH
16. DATE HEARING APPEALED
\A\ I/I
MO DAY YH
7. DATE FINS COLLECTED
18. ACTUAL FINS COLLECTSO
MO DAY YH
(whole dollars)
THIS WOULD CLOSE CASE
9. COMMENTS (uptsonai - 10 Una or lea. of not more than 60 characters each)
EPA Form 7500-15
-------
RET 7550-151
ji. SPILI
^fc SPIL
ml
OIL ANO SPCC1AI. MAT CHI A Li CONTROL. QIVI3ION
SPILL REPORT
(FORM S)
O. rQH C3NTP.3L USE 3NLY
1. SPILL. IDENTIFICATION
SPILL IO NO.
I I I I I
*r*tt
b. SPCC NO.
(T/ fft« SPCC num6«r i* nac
«nr»r»rf. cempltts Ota ?*citltr
Identification Form,)
C. NPO2S NO. a/ «!>t>tlco6t*)
S ORGANIZATION (RO)
d. RO NAME (Actvmllr emu*iat tpilt)
MAILING AOO2E35
J. CITY
^STATS
h-ZlPCOOC
i. TCUCPM9NC NO.
2. LOCATION OF SPIL.L
a.RSCION &.STAT2 e. COUMTY
d. CITY
SSOGRAPMIC LOCATION
C. UATITUOC-MORTH £. bONaiTUOC-WCIT g. SUMVSY
OKS MIM ice DCS MIN J«e
i t
CT SgCT
IKCT TOMNSHIV
h. OtHKCTIONa TO SVfUL IIT*
3. SPILL INFORMATION
a. SPILL OAT:
a*" V*
OATB AftSPTCTIMS e. «S
HH Mll
C. REPORTERS TSL£PKONE NO.
f, REPORTER'S ORGANIZATION
h. GENERAL WATER 3OOY fCft»e*
INLAND
COASTAL
SB CAT
i. SPECIFIC WATER
on* anlr)
RIVCft
I OPCN WATKM
[T8MMINAU (OOCJC)
STMCAM fCf*»k)
PONO
•AY ffftamrr or Sound}
I TRlauT«RV
(•OUT (Hftbcr Ar»»t I ICAMAL
NONC
UTER aoor NAME
n
Sc. RIVER MILE INOEX (II xmm)
jp (Page 1 of 2)
SPA Form 7500-13 (R«»- 1-77) PREVIOUS S3ITION IS OBSOLETE.
(Continued on rev«rsa)
105
-------
5. REFER TO USER'S MANUAL FOR FOUR OtSIT COOES
S. CO SPILL REQUIRING SPA SUPPORT fCh.cit 4a/o»J
-rf/4/f et»«l»)
a. SPILL
SeuMCS
99" eetf*
T PARTICIPATION
TSCHNICAL ASSISTANCE
OAMASC ASSSSSMKNT/RSSTOMATION
(4-4fllt eat!*)
b. 3PILL
CAUSE
(II "99" cod* *t>*clir>
USS Of OISPCRSANTS
J | CHECK HERE If SPILL OCCURRED UNDERGROUND
e.
) S P A MAN-MOUMS INVOL.VS9 A9OVS
RSCIONAU RESPONSE TEAM fCJwe* on.)
9. CLEANUP ACCOMPLISHED (fvndf* br)
RRT NOT ACTIVATRD
SOVCRNMCNT
BUT TCLCPMONC ACTIVATSO
STATK aOVSRNMgNT
BUT A3SSM«LCO
d.
OTHCH
. EPA SPILL RSOUIPING 3ESIONAL RCSPONSS
6»/o«r)
Iff CLEANUP COSTSfn Anown;
OSC »MYSICALL¥ ON SCSNK
IN WMOLS OOULAH3
OSC MONITOKSO 9V PMON8. STC.
EKT ASSISTANCS
OAMACC ASSCSSMKNT/RSSTOnATION
11. C3 FINES COLLECTED (S3 Jnd 34 rie<«l
IN WHOLE SOLLAM3
MCeiONAL MAN-MO UBS INVOLVSO AEOve
12. COMMENTS (Including r*mor*l aitttott)
(Page 2 of 2)
SPA
7500-13 (S«». 1-79) (Hs»«>«)
106
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GLOSSARY
Amendment inspection: An inspection conducted under provisions of
40CFR112.4 by which EPA may require an amendment to a facility's SPCC
Plan following a triggering spill.
Annulus or annular space: The space between the drill stem and the wall of
the hole or casing.
Assessment: An initial monetary penalty prescribed for infractions of oil
spill or spill prevention regulations.
Barrel: 42 United States gallons at 60 degrees Fahrenheit.
Bilge: Stagnant, dirty water that gathers in the rounded, lower part of a
ship's hull.
Blowout: A wild and uncontrolled flow of subsurface formation fluids through
an oil or gas well.
Blowout preventer (BOP): A device to control formation pressure on an oil or
gas well by closing the annulus when pipe is suspended in the well or fay
closing the top of the casing at other times.
Breakout tank: A tank along a pipeline utilized for intermediate storage.
Brine: Water saturated with or containing a high concentration of salt or
salts; also, any strong saline solution containing such other salts as
calcium chloride, zinc chloride, calcium nitrate. The term may be used
to describe water produced with crude oil from a well.
Bulkhead: A wall or partition holding back earth, fire, fluids, etc.
CFR: Code of Federal Regulations.
Cantilever: A projecting beam or structure anchored at one end extending
over a space, designed to bear loads.
Casing: Large steel pipe used in an oil or gas well to "seal off" or "shut
out" water and prevent caving of loose gravel formations when drilling
and producing. When the casings are set, drilling continues through and
below the casing with a smaller bit. The overall length of this casing
is called the string of casing. More than one string inside the other
may be used in drilling the same well.
107
-------
Centrifuge: A device for the mechanical separation of solids from a liquid.
Usually used on weighted drilling muds to recover the mud and discard
solids. The centrifuge uses high-speed mechanical rotation to achieve
this separation as distinguished from the cyclone-type separator in
which the fluid energy alone provides the separating force.
Christmas tree: Assembly of fittings and valves at the top of the casing of
an oil or gas well that controls the flow of oil or gas from the well.
Circulate: The movement of fluid in a well drilling or workover operation
from the suction pit through pump, drill pipe, bit annular space in the
hole and back again to the suction pit.
Closed in: A well capable of producing oil or gas, but temporarily not
producing.
Compliance inspection: An inspection of a facility to determine the exist-
ence, implementation, and certification of an SFCC Plan.
Core: A sample of material taken from a well by means of a hollow drilling
bit. Cores are analyzed to determine their water and oil content, por-
osity, permeability, etc.
Cracking: An oil refining process of breaking down hydrocarbons into lighter
hydrocarbons of lower molecular weight.
Cut oil: Oil that contains water, also called wet oil.
Cut: Term used in refining to designate a component or narrow boiling range
fraction of crude oil.
Dash pot: A mechanical dampening device.
De-emulsifier: Breaks up water-oil emulsion.
Dessicant: A drying agent.
Development well: An oil or gas well drilled for production from an estab-
lished field or reservoir.
Disposal well: A well through which water (usually salt water) is returned
to subsurface formations.
Diversionary structures: (Figures B-3 and B-6) Devices that divert flow
from one area to another, such as ditches, pipes, culverts.
Drill pipe: Special pipe designed to withstand the torsion and tension loads
encountered in drilling.
Drilling mud: A suspension, generally aqueous, used in rotary drilling to
clean and condition the hole and to counterbalance formation pressure;
108
-------
consists of various substances in a finely divided state, among which
bentonite and barite are most common.
Dump valve: A mechanically or pneumatically operated valve used on separa-
tors, treaters, and other vessels for the purpose of draining, or "dump-
ing" a batch of oil or water.
Emulsion: Combination of water and oil.
Enforcement activity: Those actions taken by the EPA under the provisions
of particular sections of the FWPCA.
Flowline: Carries oil or gas from wellhead to first stage in processing.
Free flowing well: A well which produces oil or gas without any means of
artificial lift.
Freewater knockout: An oil/water separation tank at atmospheric pressure.
FWPCA: The Federal Water Pollution Control Act.
Gas lift: A means of stimulating flow in an oil well by aerating the fluid
column in the well with compressed gas.
Gas-oil ratio: Number of cubic feet of gas produced with a barrel of oil.
Gathering line: A pipeline, usually of small diameter, used in gathering
crude oil from the oil field to a point on a main pipeline.
Header: A section of pipe into which several sources of oil, such as well
streams, are combined.
Heater-treatar: A vessel used to break oil-water emulsion and separate oil
and water with heat.
Knot: One nautical mile per hour, equivalent to 1.15 statute miles per hour.
u
Location (drill site): Place at which a well is to be or has been drilled.
Low flash crude: Crude oil with a low ignition temperature.
Manifold: A pipe with one inlet and several outlets or one outlet with sev-
eral inlets used for collecting or distributing fluids.
Manway: An opening large enough for a man to enter; a manhole.
Offshore facility: A facility of any kind located in, on, or under the navi-
gable waters of the United States, other than a vessel or public vessel.
Oil: Any form of oil (e.g., animal, vegetable, mineral) including petroleum,
fuel oil, sludge, oil refuse and oil mixed with wastes other than
dredged spoil.
109
-------
Oil shale: A sedimentary rock containing solid organic matter (kerogen) that
yields substantial amounts of oil when heated to high temperatures.
Oil well: A well completed for the production of crude oil from at least one
oil zone or reservoir.
Onshore facility: A facility of any kind located in, on, or under any land
within the United States, other than submerged land.
Permafrost: Subsoil that remains permanently frozen.
Permeability: The permeability (or perviousness) of rock is its capacity for
transmitting a fluid. Degree of permeability depends upon the size and
shape of the pores, the size and shape of the interconnections, and the
extent of the latter. The unit of permeability is the darcy.
Pig: A device that is forced through a pipe to clean the pipe or separate
materials flowing through the pipe.
Porosity: The volume of pore space expressed as a percentage of the total
volume of the rock mass. The percentage or pores of interspaces forming
the total bulk of the material. The absorbent capacity of the material
or the volume of liquid held by the pores.
Riser: Vertical line between flowline and manifold.
Separator: A vessel used to separate oil and gas by gravity.
SPCC: Spill Prevention Control and Countermeasure (Plan).
Spill potential: The total amount of oil that may be spilled at a particular
time and place.
Sump: Tank to collect fluids from drain systems.
Tank: A bolted or welded atmospheric or pressure container designed for
receipt, storage, and discharge of oil or other liquid.
Tank battery: A group of tanks to which crude oil flows from producing wells.
Treater: Gravity separation equipment used to break an oil-water emulsion in
an oil field.
Triggering spill: A spill of over 1000 gallons or the second of two report-
able spills within 12 months at a facility subject to SPCC regulations.
USEPA: United States Environmental Protection Agency.
Vapor space: The space above the surface of a volatile liquid in a closed
container.
110
-------
Violation: An infraction of provisions of Sections 311(b)(5), 311(b)(6), or
ell(j)(2) of the FWPCA.
Viscosity: A measure of resistance to flow of a liquid.
Water flooding: In an oil field, water injection under pressure into the
formation via injection wells to displace the oil toward the producing
wells.
Well completion: In a potentially productive formation, the completion of a
well in a manner to permit production of oil or gas; the walls of the
hole above the producing layer (and within it if necessary) must be sup-
ported against collapse and the entry into the well of fluids from for-
mations other than one producing layer must be prevented. A string of
casing is always run and cemented, at least to the top of the producing
layer, for this purpose. Some geological formations require the use of
additional techniques to "complete" a well, such as casing the producing
formation and perforating the casing to make entry holes, using slotted
pipes, consolidating sand layers with chemical treatment, etc.
Well head: Equipment used at the top of a well, including casing head, tubing
head, hangers, and the Christmas tree.
Wildcat well: A well in unproved territory.
Wireline: Device which removes paraffin from the flowline.
Work over: To clean out or otherwise work on a well in order to increase or
restore production.
Work-over fluid: Any type of fluid used in workover operation to control a
well. Drilling mud, diesel oil or salt water may be used.
"308 letter": A letter written under authority of Section 308 of the FWPCA.
111
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing/
1. REPORT NO.
EPA-6QO/ 2-81-Ml.
3. RECIPIENT'S ACCESSION»NO.
4. TITLE AND SUBTITLE
Guide for Spill Prevention
Inspectors
Control and Countermeasure
5. REPORT OATH
October 1981
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Walter Unterberg and Robert M. Moorehead
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
Rockwell International
2421 West Hill crest Drive
Newbury Park, CA 91320
10. PROGRAM ELEMENT NO.
1 NE 823
J_N£
11. COf
NTRACT/GRANT NO.
68-Q3-264S
12. SPONSORING AGENCY NAME ANO ADDRESS
Municipal Environmental Research Laboratory - Cin., OH
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
13. TYPS OP REPORT ANO PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/600/14
IS. SUPPLEMENTARY NOTES
Project Officer: John S. Farlow
(201) 321-6631
16. ABSTRACT
This report is intended for use in training and guiding inspectors performing com-
pliance inspections and amendment inspections and documenting these inspections to imple-
ment the Oil Pollution Prevention Regulations promulgated in 40CFR112 for nontransporta-
tion-related onshore and offshore faciliti-es.
The report covers the SPCC regulations, the role of the SPCC inspector, the affectec
facilities, and procedures for carrying out the inspection. It contains forms for use b>
the inspector in the field and for documentation.
The use of these forms will provide nationwide uniformity in SPCC reporting. Sug-
gested procedures appear below in short form, applicable to all inspections:
The SPCC Inspector's 1-2-3
In field fill out "SPCC Inspection Field Sheet" (1 page) (EPA Form 7500-53)
If facility in compliance If facility NOT in compliance
Fill out "SPCC Inspection Sum- Fill out "SPCC Inspection Summary Sheet"
mary Sheet" (1 page) only (EPA • (1 page) (EPA Form 7500-52) and "Detailed
Form 7500-52). SPCC Documentation" (7 pagesTTEPA Form 7500-54).
Enter information in EPA-SPCC Data Bank:
Form A - Facility Identification
Form E - Inspection/Enforcement Report
Form S - Spill Report (if required)
3 -
17.
KEY WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTlFIERS/OPSN ENDED TERMS
c. COSATI Field/Group
Oils
Pollution
Prevention
Counter-measures
Inspection
Inspector's Guide
Oil Spill Prevention
SPCC
18. DISTRIBUTION STATEMENT
Release to Public
19. SECURITY CLASS (Thit Report)
UNCLASSIFIED
21. NO. OF PAGES
118
20. SECURITY CLASS (Thit page)
UNCLASSIFIED
22. PRICE
SPA Farm 2220-1 (9-73)
112
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